Final Environmental Impact Statement 

CASOTTE LANDING LNG PROJECT 

Bayou Casotte Energy LLC 

Docket Nos. PF05-9-000 and CP05-420-000 

FERC/EIS – 0193 

Federal Energy Regulatory Commission 

Office of Energy Projects 

Washington, DC 20426 

December 2006 

Cooperating Agencies: 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Final Environmental Impact Statement

CASOTTE LANDING LNG PROJECT 

December 2006 

FERC/EIS 0193

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Federal Energy Regulatory Commission 

Routing Code PJ11.2 

Washington DC 20426 

Official Business 

Penalty for Private Use 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
FEDERAL ENERGY REGULATORY COMMISSION 

WASHINGTON, D.C. 20426 

OFFICE OF ENERGY PROJECTS In Reply Refer To: 

OEP/DG2E/Gas Branch 2 

Bayou Casotte Energy, LLC 

Docket No. CP05-420-000 

TO THE PARTY ADDRESSED: 

The staff of the Federal Energy Regulatory Commission (FERC or Commission) in cooperation 

with the U.S. Coast Guard (Coast Guard); U.S. Army Corps of Engineers (COE); U.S. Environmental 

Protection Agency (EPA), U.S. Department of the Interior, Fish and Wildlife Service (FWS); U.S. 

Department of Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries 

Service (NOAA Fisheries); and the Mississippi Department of Marine Resources (MDMR) has prepared 

this final Environmental Impact Statement (EIS) for the construction and operation of the liquefied 

natural gas (LNG) import terminal and natural gas pipeline facilities, and including operation of LNG 

vessels in the waterway from the territorial seas until moored at the facility, all referred to as the Casotte 

Landing LNG Project, as proposed by Bayou Casotte Energy, LLC in the above-referenced docket. 

This final EIS was prepared to satisfy the requirements of the National Environmental Policy Act 

(NEPA). The staff concludes that approval of the Casotte Landing LNG Project, with appropriate 

mitigating measures as recommended, would have limited adverse environmental impact. The Coast 

Guard proposed action requiring NEPA, is issuance of a Letter of Recommendation (LOR) finding the 

waterway suitable for LNG vessel traffic with the conditions referenced in the Description of the 

Proposed Action (Section 2.0 in the EIS). The final EIS evaluates alternatives to the proposed actions 

(i.e., FERC’s proposed approval of the Project and the Coast Guard’s proposed action of issuing a Letter 

of Recommendation finding the waterway to be suitable for LNG vessel traffic with conditions), 

including the Coast Guard alternatives, system alternatives, alternative sites for the LNG import terminal, 

and pipeline alternatives. The final EIS also contains our Essential Fish Habitat Assessment. 

The general purpose of the Casotte Landing LNG Project is to provide up to 1.3 billion cubic feet 

per day (Bcfd) of natural gas to markets in the United States. 

The final EIS addresses the potential environmental effects of construction and operation of the 

following facilities near the City of Pascagoula in Jackson County, Mississippi: 

• a ship unloading facility with a single berth capable of receiving LNG ships with cargo 

capacities of up to 200,000 cubic meters (m3

); 

• three 160,000 m3

 (net capacity) full containment LNG storage tanks; 

• a closed-loop intermediate fluid vaporizer system utilizing cooling water from the 

adjacent Chevron Pascagoula Refinery as a heat source, sized for a normal sendout of 1.3 

Bcfd; 

• various ancillary buildings and facilities; 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
• five pipeline interconnects originating from a 1.5-mile-long, 36-inch-diameter spur ; 

• associated pipeline support facilities, including two meter stations at interconnects with 

the existing pipeline systems; and 

• integrally related nonjurisdictional facilities would include a natural gas liquid (NGL) 

extraction system and pipeline, electric transmission lines, an electric substation, a waste 

heat water circulation system, and the relocation of two of the Chevron Pascagoula 

Refinery crude oil tanker berths. 

The analysis also includes operation of LNG vessels in the waterway from the territorial seas 

until moored at the proposed LNG terminal. 

The final EIS has been placed in the public files of the FERC and is available for distribution and 

public inspection at: 

Federal Energy Regulatory Commission 

Public Reference and Files Maintenance Branch 

888 First Street N.E., Room 2A 

Washington, DC 20426 

(202) 502-8371 

A limited number of copies of the final EIS are available from the Public Reference and Files 

Maintenance Branch identified above. In addition, CD copies of the final EIS have been mailed to 

federal, state, and local agencies; elected officials; public interest groups; individuals and affected 

landowners; libraries; newspapers; and parties to these proceedings. 

In accordance with CEQ’s regulations implementing NEPA, no agency decision on a proposed 

action may be made until 30 days after the EPA publishes a NOA of the final EIS. However, the CEQ 

regulations provide an exception to this rule when an agency decision is subject to a formal internal 

process that allows other agencies or the public to make their views known. In such cases, the agency 

decision may be made at the same time the notice of the final EIS is published, allowing both periods to 

run concurrently. Should the FERC issue authorization for the Casotte Landing LNG Project for the 

proposed action, it would be subject to a 30-day rehearing period. Therefore, the FERC could issue its 

decision concurrently with the EPA’s NOA. 

Additional information about the project is available from the Commission's Office of External 

Affairs, at 1-866-208-FERC or on the FERC Internet website (http://www.ferc.gov) using the eLibrary 

link. Click on the eLibrary link, click on “General Search” and enter the docket number excluding the last 

three digits in the Docket Number field. Be sure you have selected an appropriate date range. For 

assistance, please contact FERC Online Support at: FERCOnlineSupport@ferc.gov or toll free at 1-866-

208-3676, or for TTY at (202) 502-8659. The eLibrary link on the FERC Internet website also provides 

access to the texts of formal documents issued by the Commission, such as orders, notices, and 

rulemakings. 

Information about the project is also available from the Coast Guard by contacting Captain James 

Bjostad, Captain of the Port, Sector Mobile, at (251) 441-5960. 

Magalie R. Salas, 

Secretary 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
TABLE OF CONTENTS 

Casotte Landing LNG Project 

Final Environmental Impact Statement 

i

TABLE OF CONTENTS.....................................................................................i 

LIST OF APPENDICES....................................................................................viii 

LIST OF TABLES.............................................................................................ix 

LIST OF FIGURES...........................................................................................xii 

ACRONYMS AND ABBREVIATIONS................................................................xiii 

EXECUTIVE SUMMARY..................................................................................................... ES-1

PROJECT IMPACTS................................................................................................ES-2

ALTERNATIVES CONSIDERED...........................................................................ES-9

PUBLIC INVOLVEMENT AND AREAS OF CONCERN...................................ES-11

MAJOR CONCLUSIONS ......................................................................................ES-12

1.0 INTRODUCTION......................................................................................................... 1-1

1.1 PROJECT PURPOSE AND NEED ................................................................... 1-2 

1.2 PURPOSE AND SCOPE OF THIS STATEMENT........................................... 1-3 

1.3 PERMITS, APPROVALS, AND REGULATORY REQUIREMENTS ........... 1-5 

1.4 PUBLIC REVIEW AND COMMENT ............................................................ 1-11 

2.0 DESCRIPTION OF THE PROPOSED ACTION...................................................... 2-1

2.1 PROPOSED FACILITIES ................................................................................. 2-2 

2.1.1 LNG Terminal .......................................................................................... 2-2 

2.1.1.1 LNG Storage Tanks..................................................................... 2-5 

2.1.1.2 Vapor Handling System .............................................................. 2-7 

2.1.1.3 Vaporization System ................................................................... 2-7 

2.1.1.4 Utilities and Support Facilities .................................................... 2-8 

2.1.2 LNG Carriers .......................................................................................... 2-10

2.1.3 Pipeline Interconnects and Associated Aboveground Facilities............. 2-15

2.2 NONJURISDICTIONAL FACILITIES........................................................... 2-17 

2.3 LAND REQUIREMENTS............................................................................... 2-18

2.3.1 LNG Terminal Facilities......................................................................... 2-19

2.3.2 Pipeline and Associated Aboveground Facilities ................................... 2-20

2.4 CONSTRUCTION PROCEDURES ................................................................ 2-20 

2.4.1 LNG Terminal Facilities......................................................................... 2-25

2.4.1.1 Site Preparation ......................................................................... 2-25 

2.4.1.2 Material and Equipment Delivery ............................................. 2-26 

2.4.1.3 Marine Facilities........................................................................ 2-28 

2.4.1.4 LNG Storage Facilities .............................................................. 2-28 

2.4.2 Pipeline Interconnects and Associated Aboveground Facilities............. 2-30

2.4.2.1 General Pipeline Construction Techniques ............................... 2-30 

2.4.2.2 Special Pipeline Construction Techniques ................................ 2-34 

2.4.2.3 Associated Aboveground Facilities........................................... 2-35 

2.5 CONSTRUCTION SCHEDULE ..................................................................... 2-36 

2.6 ENVIRONMENTAL COMPLIANCE INSPECTION AND 

 MITIGATION MONITORING ....................................................................... 2-36 

2.7 OPERATION AND MAINTENANCE PROCEDURES ................................ 2-36 

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TABLE OF CONTENTS (CONTINUED) 

ii

2.7.1 LNG Terminal Facilities......................................................................... 2-36

2.7.2 LNG Carriers .......................................................................................... 2-37

2.7.3 Pipeline Interconnects and Associated Aboveground Facilities............. 2-37

2.8 SAFETY CONTROLS..................................................................................... 2-37 

2.8.1 LNG Terminal Facilities......................................................................... 2-37

2.8.1.1 Spill Containment...................................................................... 2-37 

2.8.1.2 Hazard Detection System .......................................................... 2-38 

2.8.1.3 Hazard Control System.............................................................. 2-39 

2.8.1.4 Firewater System....................................................................... 2-39 

2.8.1.5 Fail-Safe Shutdown ................................................................... 2-40 

2.8.1.6 Security System......................................................................... 2-40 

2.8.2 LNG Carriers .......................................................................................... 2-40

2.8.3 Pipeline and Associated Aboveground Facilities ................................... 2-40

2.8.3.1 Corrosion Protection and Detection System.............................. 2-41 

2.8.3.2 Emergency Response Procedures.............................................. 2-41 

2.9 FUTURE PLANS AND ABANDONMENT................................................... 2-41 

3.0 ALTERNATIVES ......................................................................................................... 3-1

3.1 INTRODUCTION.............................................................................................. 3-1 

3.2 NO ACTION OR POSTPONED ACTION ALTERNATIVE........................... 3-2 

3.2.1 Alternatives to the Coast Guard Action.................................................... 3-3

3.2.2 Energy Source and Conservation Alternatives......................................... 3-5

3.3 SYSTEM ALTERNATIVES ............................................................................. 3-6 

3.3.1 Onshore LNG Terminal System Alternatives........................................... 3-6

3.3.1.1 Existing Onshore LNG Terminals............................................... 3-6 

3.3.1.2 Approved and Proposed Onshore LNG Terminals...................... 3-7 

3.3.1.3 Conclusions Regarding Onshore LNG Terminal System 

Alternatives................................................................................ 3-10 

3.3.2 Offshore LNG Terminal System Alternatives........................................ 3-12

3.3.2.1 Shuttle Regasification Vessel .................................................... 3-12 

3.3.2.2 Gravity Based Structures........................................................... 3-15 

3.3.2.3 Reuse of Existing Offshore Platforms....................................... 3-15 

3.3.2.4 Floating Regasification Units .................................................... 3-15 

3.3.2.5 Conclusions Regarding Offshore LNG Terminal System 

Alternatives................................................................................ 3-16 

3.3.3 Pipeline System Alternatives.................................................................. 3-18

3.4 LNG TERMINAL SITE ALTERNATIVES.................................................... 3-18 

3.4.1 Local Siting Alternatives........................................................................ 3-18

3.5 LNG TERMINAL DESIGN ALTERNATIVES.............................................. 3-21 

3.5.1 Terminal Slip Configuration Alternatives .............................................. 3-21

3.5.2 Vaporization Technology Alternatives................................................... 3-23

3.5.2.1 Submerged Combustion Vaporization....................................... 3-24 

3.5.2.2 Shell and Tube Vaporization with Gas Fired Heaters ............... 3-24 

3.5.2.3 Intermediate Fluid Vaporization................................................ 3-25 

3.5.2.4 Open Rack Vaporization ........................................................... 3-25 

3.5.2.5 Ambient Air Heated Vaporization............................................. 3-26 

3.5.2.6 Vaporization Technology Alternatives Conclusions................. 3-26 

3.5.3 Electrical Power System Alternatives .................................................... 3-27

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
TABLE OF CONTENTS (CONTINUED) 

iii

3.6 PIPELINE INTERCONNECT ALTERNATIVES .......................................... 3-27 

3.6.1 Pipeline Route Alternatives.................................................................... 3-27

3.6.2 Aboveground Facility Siting Alternatives.............................................. 3-30

3.7 DREDGED MATERIAL PLACEMENT ALTERNATIVES ......................... 3-31 

3.7.1 Construction Dredging Placement Alternatives ..................................... 3-31

3.7.1.1 Confined Aquatic Disposal........................................................ 3-31 

3.7.1.2 Upland Confined Disposal ........................................................ 3-33 

3.7.1.3 Beneficial Use ........................................................................... 3-33 

3.7.1.4 Offshore Disposal...................................................................... 3-34 

3.7.2 Maintenance Dredging Placement Alternatives ..................................... 3-34

3.7.3 Conclusions Regarding Dredged Material Placement Alternatives ....... 3-35

4.0 ENVIRONMENTAL ANALYSIS ............................................................................... 4-1

4.1 GEOLOGY......................................................................................................... 4-1 

4.1.1 Geologic Setting ....................................................................................... 4-1

4.1.2 Mineral Resources .................................................................................... 4-2

4.1.3 Geologic Hazards ..................................................................................... 4-3

4.1.3.1 Seismicity and Faulting ............................................................... 4-3 

4.1.3.2 Soil Liquefaction ......................................................................... 4-3 

4.1.3.3 Landslides/Slope Stability ........................................................... 4-4 

4.1.3.4 Subsidence................................................................................... 4-4 

4.1.3.5 Flooding/Storm Damage ............................................................. 4-5 

4.1.3.6 Shoreline Erosion ........................................................................ 4-6 

4.1.4 Blasting..................................................................................................... 4-6

4.1.5 Paleontological Resources........................................................................ 4-6

4.2 SOILS AND SEDIMENTS................................................................................ 4-6 

4.2.1 Soil Resources .......................................................................................... 4-6

4.2.1.1 Soil Characteristics...................................................................... 4-8 

4.2.1.2 Prime Farmland ......................................................................... 4-10 

4.2.1.3 Hydric Soils............................................................................... 4-10 

4.2.1.4 Compaction Potential ................................................................ 4-10 

4.2.1.5 Erosion....................................................................................... 4-11 

4.2.1.6 Revegetation.............................................................................. 4-11 

4.2.1.7 Soil Contamination.................................................................... 4-11 

4.2.2 Sediments ............................................................................................... 4-12

4.2.2.1 Physical Characteristics of the Sediments ................................. 4-13 

4.2.2.2 Chemical Characteristics of the Sediments ............................... 4-13 

4.2.2.3 Biological Testing of the Sediments.......................................... 4-14 

4.3 WATER RESOURCES.................................................................................... 4-15 

4.3.1 Groundwater........................................................................................... 4-15

4.3.1.1 Hydrogeologic Setting............................................................... 4-15 

4.3.1.2 Public Water Supply and Wells................................................. 4-16 

4.3.1.3 Groundwater Quality ................................................................. 4-16 

4.3.1.4 Impacts and Mitigation.............................................................. 4-16 

4.3.2 Surface Water ......................................................................................... 4-19

4.3.2.1 Environmental Setting ............................................................... 4-19 

4.3.2.2 Impact and Mitigation ............................................................... 4-20 

4.4 VEGETATION AND WETLANDS................................................................ 4-28 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
TABLE OF CONTENTS (CONTINUED) 

iv

4.4.1 Habitat/Community Types ..................................................................... 4-28

4.4.1.1 LNG Terminal Facilities............................................................ 4-29 

4.4.1.2 Interconnect Pipeline and Associated Aboveground 

 Facilities .................................................................................... 4-29 

4.4.2 Invasive Plant Species ............................................................................ 4-30

4.4.3 Wetlands................................................................................................. 4-30

4.4.3.1 LNG Terminal Facilities............................................................ 4-31 

4.4.3.2 Interconnect Pipeline Route....................................................... 4-33 

4.4.3.3 Nonjurisdictional Facilities........................................................ 4-33 

4.4.4 Impact and Mitigation ............................................................................ 4-33

4.4.4.1 Upland Vegetation..................................................................... 4-34 

4.4.4.2 Wetlands.................................................................................... 4-35 

4.4.5 Compensatory Mitigation....................................................................... 4-35

4.5 WILDLIFE AND AQUATIC RESOURCES .................................................. 4-36 

4.5.1 Terrestrial Wildlife ................................................................................. 4-36

4.5.1.1 Existing Terrestrial Wildlife Habitats........................................ 4-36 

4.5.1.2 Unique or Sensitive Wildlife Habitats....................................... 4-38 

4.5.1.3 Impacts and Mitigation.............................................................. 4-38 

4.5.2 Estuarine and Marine Resources ............................................................ 4-40

4.5.2.1 Existing Estuarine and Marine Resource Habitats .................... 4-41 

4.5.2.2 Impacts and Mitigation.............................................................. 4-44 

4.5.3 Freshwater Resources............................................................................. 4-51

4.5.4 Essential Fish Habitat ............................................................................. 4-52

4.5.4.1 Conclusions of EFH Assessment............................................... 4-53 

4.6 THREATENED, ENDANGERED, AND OTHER SPECIAL 

 STATUS SPECIES .......................................................................................... 4-54 

4.6.1 Federally Listed Threatened and Endangered Species ........................... 4-54

4.6.1.1 Mammals ................................................................................... 4-58 

4.6.1.2 Fish ............................................................................................ 4-62 

4.6.1.3 Reptiles...................................................................................... 4-65 

4.6.1.4 Birds .......................................................................................... 4-66 

4.6.2 Other Special Status Species .................................................................. 4-67

4.6.2.1 State Listed Threatened and Endangered Species ..................... 4-67 

4.6.2.2 Marine Mammals....................................................................... 4-72 

4.6.2.3 Migratory Birds ......................................................................... 4-72 

4.6.3 Conclusions and Recommendations....................................................... 4-72

4.7 LAND USE, RECREATION AND VISUAL RESOURCES.......................... 4-73 

4.7.1 Land Use................................................................................................. 4-73

4.7.1.1 Terminal Site ............................................................................. 4-73 

4.7.1.2 Pipeline Interconnect System .................................................... 4-76 

4.7.1.3 Extra Work Space and Staging Areas........................................ 4-76 

4.7.1.4 Above ground Facilities Outside the Proposed 

 Terminal Site ............................................................................. 4-76 

4.7.1.5 Access Roads............................................................................. 4-77 

4.7.1.6 Disposal of Spoils from Slip Creation....................................... 4-77 

4.7.1.7 Nonjurisdictional Facilities........................................................ 4-77 

4.7.2 Existing Residences and Planned Developments ................................... 4-78

4.7.3 Recreation and Special Interest Areas .................................................... 4-78

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
TABLE OF CONTENTS (CONTINUED) 

v

4.7.3.1 Gulf Islands National Seashore ................................................. 4-78 

4.7.3.2 Grand Bay National Reserve, Mississippi................................. 4-79 

4.7.3.3 Port of Pascagoula ..................................................................... 4-79 

4.7.3.4 Recreational Boating and Fishing.............................................. 4-79 

4.7.4 Visual Resources .................................................................................... 4-80

4.7.5 Coastal Zone Management (CZM) consistency ..................................... 4-80

4.8 SOCIOECONOMICS ...................................................................................... 4-81 

4.8.1 Population............................................................................................... 4-81

4.8.2 Economy and Employment .................................................................... 4-82

4.8.3 Housing................................................................................................... 4-83

4.8.4 Property Values ...................................................................................... 4-83

4.8.5 Government Revenue ............................................................................. 4-83

4.8.6 Public Services ....................................................................................... 4-84

4.8.7 Local Commerce .................................................................................... 4-85

4.8.8 Environmental Justice............................................................................. 4-85

4.8.8.1 Racial and Economic Composition ........................................... 4-85 

4.8.8.2 Public Health ............................................................................. 4-86 

4.8.8.3 Public and Community Participation......................................... 4-86 

4.8.8.4 Conclusions Regarding Environmental Justice ......................... 4-86 

4.9 TRANSPORTATION ...................................................................................... 4-86 

4.9.1 Marine Transportation ............................................................................ 4-86

4.9.2 Land Transportation ............................................................................... 4-88

4.10 CULTURAL RESOURCES............................................................................. 4-89 

4.10.1 Cultural Resources Assessment.............................................................. 4-89

4.10.1.1 LNG Terminal ........................................................................... 4-89 

4.10.1.2 Natural Gas Pipeline System Interconnects............................... 4-89 

4.10.1.3 Dredged Material Placement/Disposal Location(s)................... 4-89 

4.10.1.4 NGL Pipeline............................................................................. 4-89 

4.10.1.5 Electric Transmission Lines ...................................................... 4-90 

4.10.1.6 Waste Heat Delivery and Cool Water Return System............... 4-90 

4.10.1.7 Additional Extra Workspace Areas ........................................... 4-90 

4.10.1.8 Transit Waterway ...................................................................... 4-90 

4.10.2 Unanticipated Discovery Plan ................................................................ 4-90

4.10.3 Native American Consultation ............................................................... 4-90

4.10.4 Impact and Mitigation ............................................................................ 4-91

4.11 AIR QUALITY AND NOISE.......................................................................... 4-91 

4.11.1 Air Quality.............................................................................................. 4-91

4.11.1.1 Regional Climate....................................................................... 4-91 

4.11.1.2 Existing Air Quality .................................................................. 4-91 

4.11.1.3 Regulatory Requirements for Air Quality ................................. 4-93 

4.11.1.4 Air Quality Impacts and Mitigation........................................... 4-98 

4.11.2 Noise 4-106

4.11.2.1 Noise Regulations.................................................................... 4-106 

4.11.2.2 Existing Noise Levels.............................................................. 4-106 

4.11.2.3 Impact and Mitigation ............................................................. 4-108 

4.12 RELIABILITY AND SAFETY ..................................................................... 4-111 

4.12.1 LNG Hazards........................................................................................ 4-113

4.12.2 Cryogenic Design and Technical Review............................................. 4-114

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TABLE OF CONTENTS (CONTINUED) 

vi

4.12.3 Storage and Retention Systems ............................................................ 4-119

4.12.4 Siting Requirements – Thermal and Vapor Dispersion 

 Exclusion Zones ................................................................................... 4-125

4.12.4.1 Regulatory Requirements ........................................................ 4-125 

4.12.4.2 Impoundment Systems and Design Spills ............................... 4-126 

4.12.4.3 Thermal Exclusion Zone ......................................................... 4-128 

4.12.4.4 Vapor Dispersion Zone............................................................ 4-129 

4.12.5 Marine Safety ....................................................................................... 4-130

4.12.5.1 Pascagoula Bar, Horn Island Pass, Lower Pascagoula, 

 and Bayou Casotte Channels ................................................... 4-136 

4.12.5.2 Requirements for LNG Carrier Operations in 

 Port of Pascagoula ................................................................... 4-139 

4.12.5.3 Environmental Impacts Associated with 

 Coast Guard Actions................................................................ 4-144 

4.12.5.4 LNG Carrier Safety ................................................................. 4-148 

4.12.5.5 Conclusions on Marine Traffic Safety..................................... 4-155 

4.12.6 Terrorism and Security Issues .............................................................. 4-155

4.12.7 Pipeline Facilities ................................................................................. 4-157

4.12.7.1 Safety Standards ...................................................................... 4-157 

4.12.7.2 Pipeline Accident Data ............................................................ 4-161 

4.12.7.3 Impact on Public Safety........................................................... 4-163 

4.12.8 Conclusions on Safety Issues ............................................................... 4-164

4.13 CUMULATIVE IMPACTS ........................................................................... 4-165 

4.13.1 Geology ................................................................................................ 4-167

4.13.2 Soils and Sediments.............................................................................. 4-167

4.13.3 Water Resources................................................................................... 4-169

4.13.4 Vegetation and Wetlands...................................................................... 4-170

4.13.4.1 Vegetation................................................................................ 4-170 

4.13.4.2 Wetlands.................................................................................. 4-170 

4.13.5 Wildlife and Aquatic Resources ........................................................... 4-171

4.13.5.1 Wildlife.................................................................................... 4-171 

4.13.5.2 Aquatic Resources................................................................... 4-172 

4.13.6 Land Use, Recreation, and Visual Resources....................................... 4-173

4.13.6.1 Land Use.................................................................................. 4-173 

4.13.6.2 Recreation................................................................................ 4-173 

4.13.6.3 Visual Resources ..................................................................... 4-174 

4.13.7 Socioeconomics.................................................................................... 4-174

4.13.7.1 Economy and Employment ..................................................... 4-175 

4.13.7.2 Housing ................................................................................... 4-175 

4.13.7.3 Infrastructure and Services ...................................................... 4-176 

4.13.8 Transportation....................................................................................... 4-176

4.13.8.1 Marine Transportation............................................................. 4-176 

4.13.8.2 Land Transportation ................................................................ 4-177 

4.13.9 Air Quality and Noise........................................................................... 4-178

4.13.10 Reliability and Safety ........................................................................... 4-181

4.13.11 Conclusions .......................................................................................... 4-182 

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TABLE OF CONTENTS (CONTINUED) 

vii

5.0 CONCLUSIONS AND RECOMMENDATIONS ...................................................... 5-1

5.1 SUMMARY OF THE STAFF’S ENVIRONMENTAL ANALYSIS................ 5-1 

5.1.1 Geology .................................................................................................... 5-1

5.1.2 Soils and Sediments.................................................................................. 5-2

5.1.3 Water Resources....................................................................................... 5-2

5.1.4 Vegetation and Wetlands.......................................................................... 5-3

5.1.5 Wildlife and Aquatic Resources ............................................................... 5-4

5.1.6 Threatened, Endangered, and Other Special Status Species..................... 5-4

5.1.7 Land Use, Recreation, and Visual Resources........................................... 5-5

5.1.8 Socioeconomics........................................................................................ 5-6

5.1.9 Transportation and Traffic........................................................................ 5-6

5.1.10 Cultural Resources.................................................................................... 5-7

5.1.11 Air Quality and Noise............................................................................... 5-7

5.1.12 Reliability and Safety ............................................................................... 5-8

5.1.13 Alternatives............................................................................................. 5-10

5.2 FERC STAFF’S RECOMMENDED MITIGATION ...................................... 5-12 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
LIST OF APPENDICES 

viii

APPENDIX A FINAL EIS DISTRIBUTION LIST 

APPENDIX B BAYOU CASOTTE ENERGY’S PLAN AND PROCEDURES 

APPENDIX C STORMWATER POLLUTION PREVENTION PLAN FOR 

CONSTRUCTION ACTIVITIES 

APPENDIX D SPILL PREVENTION CONTROL AND 

COUNTERMEASURE PLAN FOR CONSTRUCTION 

ACTIVITIES 

APPENDIX E SECTION 103 EVALUATION AND DREDGED MATERIAL 

MANAGEMENT PLAN 

APPENDIX F ESSENTIAL FISH HABITAT ASSESSMENT 

APPENDIX G BAYOU CASOTTE ENERGY LETTER OF INTENT AND 

THE U.S. COAST GUARD WATERWAY SUITABILITY 

REPORT LETTERS 

APPENDIX H COMMENTS ON THE DRAFT EIS AND RESPONSES 

APPENDIX I REFERENCES 

APPENDIX J LIST OF PREPARERS 

APPENDIX K SUBJECT INDEX 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
LIST OF TABLES 

ix

Number Title Page

1.3-1 Major Permits, Approvals, and Consultations for the Casotte 

Landing Project............................................................................................ 1-7 

1.4-1 Primary Issues Identified and Comments Received During the Public 

Scoping Process for the Casotte Landing LNG Project............................ 1-12 

2.1.3-1 Aboveground Facilities Associated with the Proposed Casotte 

Landing Project.......................................................................................... 2-17 

2.3-1 Summary of Land Requirements Associated with the Casotte 

Landing Project Pipeline............................................................................ 2-19 

2.8.1-1 Federal Siting and Design Requirements for LNG Facilities .................... 2-38 

3.3.1-1 Approved and Proposed Onshore LNG Terminals Along the Gulf of 

Mexico ......................................................................................................... 3-8 

3.3.2-1 Approved and Proposed Offshore LNG Terminals Located along the 

Gulf of Mexico or South Atlantic Coasts .................................................. 3-13 

3.4.1-1 Comparison of Local Siting Alternatives for the Proposed Casotte 

Landing Project.......................................................................................... 3-19 

3.5.1-1 Terminal Slip Configuration Alternatives for the Proposed Casotte 

Landing Project.......................................................................................... 3-23 

3.6.1-1 Comparison of Route Alternatives to the Proposed Pipeline 

Interconnect Spur for the Casotte Landing Project.................................... 3-30 

4.2.1-1 Major Characteristics of Soils Impacted by the Proposed Casotte 

Landing LNG Project................................................................................... 4-9 

4.3.2-1 Onshore Waterbodies Affected by the Proposed Casotte Landing 

Project ........................................................................................................ 4-20 

4.4.3-1 Wetlands Affected by Construction and Operation of the Proposed 

Casotte Landing Project............................................................................. 4-32 

4.5.1-1 Typical Wildlife Species that Occur in the Vicinity of the Proposed 

Casotte Landing Project............................................................................. 4-37 

4.5.2-1 Typical Estuarine Benthic Species that Occur in the Vicinity of the 

Proposed Casotte Landing Project............................................................. 4-41 

4.5.2-2 Managed Fish and Shellfish Resources with Potential for EFH in the 

Casotte Landing Project Area .................................................................... 4-43 

4.6.1-1 Federally Listed Species Eliminated From Further Consideration for 

the Casotte Landing LNG Project Area..................................................... 4-55 

4.6.1-2 Federally Listed Species Potentially Affected in the Casotte Landing 

LNG Project Area ...................................................................................... 4-59 

4.6.2-1 State Listed Species Eliminated From Further Consideration for the 

Casotte Landing LNG Project Area........................................................... 4-68 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
LIST OF TABLES (CONTINUED) 

x

4.6.2-2 State Listed Species Potentially Affected in the Casotte Landing 

LNG Project Area ...................................................................................... 4-70 

4.7-1 Acreage Used During Construction........................................................... 4-74 

4.7-2 Acreage Converted from its Current Designation During Operation ........ 4-75 

4.8.1-1 Selected Socioeconomic Statistics............................................................. 4-81 

4.8.2-1 Employment Statistics ............................................................................... 4-82 

4.8.5-1 Estimated Local, County and State Taxes ................................................. 4-84 

4.8.6-1 Local Fire, Police, and Ambulance............................................................ 4-84 

4.11.1-1 National Ambient Air Quality Standards for the Casotte Landing 

Project ........................................................................................................ 4-92 

4.11.1-2 PSD Class I and Class II Increments ......................................................... 4-94 

4.11.1-3 Estimated Emissions from LNG Terminal and Pipeline Interconnect 

Construction............................................................................................. 4-100 

4.11.1-4 Estimated Stationary Source and Mobile Marine Vessel Emissions 

for Operation of Casotte Landing LNG Terminal ................................... 4-102 

4.11.1-6 Class I Analysis – Primary and Secondary Emission Sources................. 4-105 

4.11.1-7 Class I Visibility Impairment Analysis.................................................... 4-105 

4.11.1-8 Class I Deposition Analysis..................................................................... 4-105 

4.11.2-1 Nearest Noise Sensitive Areas................................................................. 4-106 

4.11.2-2 Background Noise Levels at Nearest Noise Sensitive Areas................... 4-108 

4.11.2-3 Estimated Construction Equipment Noise............................................... 4-109 

4.11.2-4 Equipment Quantities and Sound Power Levels Used in Noise 

Modeling.................................................................................................. 4-110 

4.11.2-5 Predicted Ldn Noise Levels at Nearest NSA........................................... 4-110 

4.12.4-1 Impoundment Areas................................................................................. 4-128 

4.12.4-2 Thermal Exclusion Zones ........................................................................ 4-129 

4.12.5-1 Channel Characteristics for Route that Would be Used by LNG 

Carriers Calling on the Proposed LNG Terminal .................................... 4-137 

4.12.5-2 Minimum Striking Speed to Penetrate LNG Cargo Tanks ...................... 4-151 

4.12.5-3 LNG Spills on Water ............................................................................... 4-154 

4.12.7-1 Natural Gas Service Incidents by Cause.................................................. 4-161 

4.12.7-2 Outside Forces Incidents by Cause (1970-1984) ..................................... 4-162 

4.12.7-3 External Corrosion by Level of Control (1970-1984) ............................. 4-163 

4.12.7-4 Annual Average Fatalities - Natural Gas Transmission and Gathering 

Systems .................................................................................................... 4-163 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
LIST OF TABLES (CONTINUED) 

xi

4.12.7-5 Nationwide Accidental Deathsa............................................................... 4-164 

4.13-1 Existing or Proposed Activities Cumulatively Affecting Resources of 

Concern for the Casotte Landing Project................................................. 4-167 

4.13.2-1 Estimated Volumes of Dredged Material for Current and Proposed 

Projects .................................................................................................... 4-168 

4.13.4-1 Wetland Impacts Associated with the Proposed LNG Terminal 

Projects (acres)......................................................................................... 4-170 

4.13.8-1 Estimated Number of Ship Calls for the Proposed LNG Terminal 

Projects and the Refinery Expansion Project.......................................... 4-177 

4.13.9-1 Proposed LNG Terminal Projects and the Refinery Expansion 

Project Emissions Summary .................................................................... 4-179 

4.13.9-2 Summary of Class II Area Impacts Resulting From the Casotte 

Landing LNG and LNG Clean Energy Projects ...................................... 4-180 

4.13.9-3 Summary of Class II Area Impacts Resulting From the Casotte 

Landing LNG and LNG Clean Energy Projects ...................................... 4-181 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
LIST OF FIGURES 

xii

Number Title Page

2.1-1 Proposed Casotte Landing Project General Project Location...................... 2-3 

2.1.1-1 Proposed Casotte Landing Project LNG Terminal Site Layout Ship 

Berth and Unloading Facilities .................................................................... 2-4 

2.1.1-2 Proposed Casotte Landing Project Conceptual Design of the LNG 

Storage Tanks .............................................................................................. 2-6 

2.1.2-1 Proposed Casotte Landing Project Navigation Routes to the Port of 

Pascagoula ................................................................................................. 2-11 

2.1.3-1 Proposed Casotte Landing Project Pipeline Interconnect System ............. 2-16 

2.3.2-1 Proposed Casotte Landing Project Typical Pipeline Construction 

Right-of-Way Cross Sections .................................................................... 2-21 

2.3.2-2 Proposed Casotte Landing Project Typical Pipeline Construction 

Right-of-Way Cross Sections .................................................................... 2-22 

2.3.2-3 Proposed Casotte Landing Project Typical Pipeline Construction 

Right-of-Way Cross Sections .................................................................... 2-23 

2.3.2-4 Proposed Casotte Landing Project Typical Pipeline Construction 

Right-of-Way Cross Sections .................................................................... 2-24 

2.4.1-1 Proposed Casotte Landing Project Dredged Material Placement 

Location ..................................................................................................... 2-27 

2.4.2-1 Proposed Casotte Landing Project Typical Pipeline Construction 

Sequence .................................................................................................... 2-31 

3.4.1-1 Proposed Casotte Landing Project Local Siting Alternatives.................... 3-20 

3.5.1-1 Proposed Casotte Landing Project Terminal Slip Configuration 

Alternatives................................................................................................ 3-22 

3.6.1-1 Proposed Casotte Landing Project Route Alternatives to the 

Proposed Pipeline Interconnect Spur......................................................... 3-29 

3.7.1-1 Proposed Casotte Landing Project Dredged Material Placement 

Alternatives................................................................................................ 3-32 

4.11.2-1 Proposed Casotte Landing Project Nearest Noise Sensitive Areas.......... 4-107 

H-1 Examples of Single Containment Tanks.................................................. 4-122 

H-3 Examples of Double Containment Tanks ................................................ 4-123 

H-4 xamples of Full Containment Tanks........................................................ 4-124 

4.12.5-1 Proposed Casotte Landing Project Potential Sensitive Resources 

Along Ship Route..................................................................................... 4-146 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ACRONYMS AND ABBREVIATIONS 

xiii

ACHP Advisory Council on Historic Preservation 

ASD Azimuthing Stern Drive 

BA Biological Assessment 

Bayou Casotte Energy Bayou Casotte Energy LLC 

BCDMMS Bayou Casotte Dredged Material Management Site 

Bcfd billion cubic feet per day 

bgs below ground surface 

Bienville Bienville Offshore Energy 

BMP Best Management Practices 

BOG boil-off gas 

BTU British Thermal Units 

CAAA Clean Air Act Amendments 

Calypso Calypso LNG Deepwater Port Project 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

Chevron Chevron U.S.A. Inc. 

CI compression ignition 

CMP Mississippi Coastal Management Program 

CO2 carbon dioxide 

Coast Guard U.S. Coast Guard 

COE U.S. Army Corps of Engineers 

Cohart Cohart Refractory 

Corning Corning Glass Works 

COTP Captain of the Port 

Cove Point Dominion Cove Point LNG, LP 

CPT Cone Penetrometer Test 

CT1 Cooling Tower 1 

CT2 Cooling Tower 2 

CZM Coastal Zone Management 

CZMA Coastal Zone Management Act of 1972 

dBA decibels on the A-weighted scale 

Distrigas Distrigas of Massachusetts LLC 

DMMP Dredged Materials Management Plan 

DOE U.S. Department of Energy 

DOT U.S. Department of Transportation 

DWT deadweight tonnage 

EEM estuarine emergent 

EFH Essential fish habitat 

EGS Emergency Group Sites 

EIS Environmental Impact Statement 

EPA U.S. Environmental Protection Agency 

EPC contractor Engineering, Procurement and Construction contractor 

ESA Endangered Species Act of 1973 

ESS or estuarine scrub-shrub 

F Fahrenheit 

FCCU Fluid Catalytic Cracking Unit 

FEMA Federal Emergency Management Agency 

FERC or Commission Federal Energy Regulatory Commission 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ACRONYMS AND ABBREVIATIONS (CONTINUED) 

xiv

FIS Flood Insurance Study Model 

FMC Fishery Management Councils 

FMSC Federal Maritime Security Coordinators 

FSO Facility Security Officer 

FSRU floating, storage and regasification unit 

ft/ft foot/foot 

ft3 cubic feet 

FWS U.S. Fish and Wildlife Service 

g gravity 

GIWW Gulf Intracoastal Waterway 

gpm gallons per minute 

Gulf Gateway Gulf Gateway Energy Bridge 

Gulf LNG Gulf LNG Energy, LLC 

H&K Hoover & Keith, Inc. 

HAP hazardous air pollutant 

HCAs high consequence areas 

HDD horizontal directional drill 

HI Horn Island 

ICE internal combustion engines 

IFV intermediate fluid vaporizer 

IMO International Maritime Organization 

ISPS International Ship and Port Facility Security 

Jackson Chamber Jackson County Chamber of Commerce 

kPa kilopascals 

Ld equivalent sound level daytime 

Ln equivalent sound level nighttime 

LNG liquefied natural gas 

LOI Letter of Intent 

LOR Letter of Recommendation 

LPG liquid petroleum gas 

m3

 cubic meters 

MACT Maximum Achievable Control Technology 

Main Pass Main Pass Energy Hub 

MARAD U.S. Maritime Administration 

MARSEC Maritime Security 

mcy million cubic yards 

MDEQ Mississippi Department of Environmental Quality 

MDMR Mississippi Department of Marine Resources 

MEOW maximum envelope of water 

MLLW mean lower low water 

MMBTU/hr million British thermal units per hour 

MMNS-NHP Mississippi Museum of Natural Science-Natural Heritage Program 

MPC Mississippi Power Company 

MPRSA Marine Protection, Research, and Sanctuaries Act 

MSA Magnuson-Stevens Fishery Conservation and Management Act 

NAAQS National Ambient Air Quality Standards 

NC net capacity 

NEPA National Environmental Policy Act of 1969 

NERR National Estuary Research Reserve 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ACRONYMS AND ABBREVIATIONS (CONTINUED) 

xv

NESHAP National Emissions Standards for Hazardous Air Pollutants 

NGA Natural Gas Act 

NGL natural gas liquids 

NHPA National Historic Preservation Act 

NM nautical mile 

NO2 Nitrogen Dioxide 

NOAA Fisheries National Oceanic and Atmospheric Administration, National Marine 

Fisheries Service 

NOI Notice of Intent 

NOx Oxides of Nitrogen 

NPDES National Pollutant Discharge Elimination System 

NRHP National Register of Historic Places 

NSA Noise Sensitive Areas 

NSPS New Source Performance Standards 

NSR New Source Review 

NTUs Nephelometric Turbidity Units 

O3 ozone 

ODMDS Ocean Dredged Material Disposal Site 

OPS Office of Pipeline Safety 

ORV open rack vaporizers 

Pb lead 

PEM palustrine emergent 

PFO palustrine forested 

Pilots Pascagoula Bar Pilots Association 

Plan Bayou Casotte Energy’s Upland Erosion Control, Revegetation, and 

Maintenance Plan 

PM10 particulate matter with an aerodynamic diameter less than or equal to 

10 microns 

Procedures Wetland and Waterbody Construction and Mitigation Procedures 

Project Casotte Landing Natural Gas Import Terminal Project 

PSD prevention of significant deterioration 

psig pounds per square inch gauge 

PSS palustrine scrub-shrub 

Quest Quest Consultants, Inc 

re: 1 μPa reference pressure of 1 micropascal 

Refinery Chevron Pascagoula Refinery 

RMP risk management plan 

RPT rapid phase transition 

SAP Sampling and Analysis Protocol 

SCFH standard cubic feet per hour 

SCV submerged combustion vaporization 

SHPO State Historic Preservation Officer 

SMA Special Management Area 

SO2 sulphur dioxide

Southern Southern LNG Inc. 

SPCC Spill Prevention, Control and Countermeasure Plan 

SRV shuttle regasification vessels 

SSURGO Soil Survey Geographic 

STV shell and tube vaporizers 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ACRONYMS AND ABBREVIATIONS (CONTINUED) 

xvi

SUEZ SUEZ Energy North America, Inc. 

SVR ship vapor return 

SWPPP Stormwater Pollution Prevention Plan 

Tcf trillion cubic feet 

TNT trinitrotoluene 

tpy tons per year 

Trunkline Trunkline LNG Company, LLC 

TSS total suspended solids 

USC United States Code 

USDA U.S. Department of Agriculture 

USDHS U.S. Department of Homeland Security 

VOCs volatile organic compounds 

VOLs volatile organic liquids 

WSA Waterway Suitability Assessment 

WSR Waterway Suitability Report 

yd3 cubic yard 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ES-1

EXECUTIVE SUMMARY 

This final environmental impact statement (EIS) for the Casotte Landing LNG Project (Project) 

has been prepared by the staff of the Federal Energy Regulatory Commission (FERC or Commission) to 

fulfill the requirements of the National Environmental Policy Act (NEPA) and the Commission’s 

implementing regulations under Title 18, Code of Federal Regulations, Part 380. The purpose of this 

document is to inform the public and the permitting agencies about the potential adverse and beneficial 

environmental impacts of the proposed Project and its alternatives; and to recommend mitigation 

measures that would avoid or reduce any significant adverse impact to the maximum extent possible. 

This document has been prepared in coordination with the Mississippi Department of Environmental 

Quality (MDEQ), Gulf States Marine Fisheries Commission, Jackson County Port Authority, and our 

cooperating agencies including the U.S. Army Corps of Engineers (COE); U.S. Department of Homeland 

Security, U.S. Coast Guard (Coast Guard); U.S. Department of the Interior, Fish and Wildlife Service 

(FWS); U.S. Department of Commerce, National Oceanic and Atmospheric Administration, National 

Marine Fisheries Service (NOAA Fisheries); U.S. Department of Transportation (DOT); U.S. 

Environmental Protection Agency (EPA); and the Mississippi Department of Marine Resources 

(MDMR). 

THE VERTICAL LINE IN THE MARGIN IDENTIFIES TEXT THAT HAS BEEN MODIFIED IN 

THE FINAL EIS 

AND DIFFERS FROM THE CORRESPONDING TEXT IN THE DRAFT EIS. 

The FERC is the federal agency responsible for authorizing applications to construct and operate 

onshore liquefied natural gas (LNG) import and interstate natural gas transmission facilities. The Coast 

Guard is the federal agency responsible for issuing a Letter of Recommendation (LOR) regarding the 

suitability of waterways for LNG marine traffic and it is this proposed action under Title 33 Code of 

Federal Regulations (CFR) Part 127.009 which is addressed in this EIS. 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 United States Code (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 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 marine traffic in and around the LNG facility. 

Bayou Casotte Energy LLC (Bayou Casotte Energy) seeks authorization to site, construct, and 

operate a liquefied natural gas (LNG) terminal and ancillary facilities to connect the proposed LNG 

terminal to existing natural gas transmission facilities near Pascagoula, Mississippi. Bayou Casotte 

Energy’s proposed facilities would transport a nominal rate of 1.3 billion cubic feet per day (Bcfd) of 

imported LNG to the United States markets that can be accessed through interconnects with five existing 

interstate pipelines in the vicinity of the proposed terminal site. 

The proposed LNG terminal and pipeline facilities would include: 

• a ship unloading facility with a single berth capable of receiving LNG ships with cargo 

capacities of up to 200,000 cubic meters (m3

); 

• three 160,000 m3

 (net capacity) full containment LNG storage tanks; 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ES-2

• a closed-loop intermediate fluid vaporizer system utilizing cooling water from the adjacent 

Chevron Pascagoula Refinery as a heat source, sized for a nominal sendout of 1.3 Bcfd; 

• various ancillary buildings and facilities; 

• five pipeline interconnects originating from a 1.5-mile-long, 36-inch-diameter spur ; and 

• associated pipeline support facilities, including two meter stations at interconnects with the 

existing pipeline systems. 

In addition to these proposed jurisdictional facilities, the Casotte Landing Project would also 

involve a number of other integrally related facilities that are not regulated by the FERC. These 

nonjurisdictional facilities would include a natural gas liquid (NGL) extraction system and pipeline, 

electric transmission lines, an electric substation, and a waste heat, water circulation system. The 

relocation of two crude oil tanker berths at the Pascagoula Refinery is also planned due to the 

construction of the proposed marine terminal slip. 

PROJECT IMPACTS 

The environmental issues associated with construction and operation of the Casotte Landing LNG 

Project, including impacts from the transit of LNG vessels, support vessels, Coast Guard and other law 

enforcement security and patrol vessels along the waterway from the territorial seas to the proposed LNG 

terminal are analyzed in this final EIS using information provided by Bayou Casotte Energy and further 

developed from data requests; field investigations by the Commission staff; literature research; alternative 

analyses; comments from federal, state, and local agencies; and input received from public organizations 

and individual citizens. 

Land requirements for the proposed LNG terminal site would total approximately 259.4 acres 

during construction and operation. Construction of the proposed pipeline interconnects and meter stations 

would affect an additional 17.4 acres of land. Of this amount, the two interconnect meter stations 

(1.8 acres) and the permanent pipeline right-of-way associated with the pipeline interconnect spur 

(6.1 acres) would encumber 7.9 acres during operations. The construction and operational land 

requirements of the nonjurisdictional Project facilities would total 36.2 and 1.8 acres, respectively. All 

land temporarily affected by construction would be allowed to revert to its original use and cover type 

following construction. 

Construction and operation of the Project would have minimal impact on geologic resources in 

the Project area, and the potential for geologic hazards or other natural events to significantly impact the 

Project is low. To minimize potential impacts associated with shoreline erosion, Bayou Casotte Energy 

would install an area of rock or concrete units on the slope parallel to the shoreline to minimize scour 

potential within the berth area from LNG ship propeller wash. During the transit along the navigation 

channels, LNG marine traffic would be operating at low speeds and would not create wakes that would 

increase the potential for shoreline erosion in the project area. The proposed LNG terminal site would be 

protected against storm surge associated with tropical storms and hurricanes of the magnitude that are 

likely to affect the Project area. Bayou Casotte Energy would construct a hurricane levee to surround the 

LNG terminal. 

The majority of the soils at the proposed terminal site consist of fill, or altered soils associated 

with previous dredge disposal operations and industrial uses. Construction of the LNG facilities would 

increase the potential for soil erosion on the site and sedimentation in adjacent waterbodies and wetlands. 

Soils along the pipeline interconnect route would also be subject to various impacts, including 

compaction and erosion. To mitigate potential impacts on soil resources in the Project area Bayou Casotte 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ES-3

Energy would implement its Upland Erosion Control, Revegetation, and Maintenance Plan (Plan) and 

Wetland and Waterbody Construction and Mitigation Procedures (Procedures), during construction, 

restoration, and operation of the LNG terminal and pipeline interconnects. In addition to our Plan and 

Procedures, Bayou Casotte Energy would develop a site-specific Stormwater Pollution Prevention Plan 

(SWPPP) as a requirement of its general permit for construction stormwater discharges. The SWPPP 

would incorporate best management practices (BMPs) as specified in our Plan, as well as guidance 

developed for erosion control and stormwater management in the State of Mississippi. Bayou Casotte 

Energy would also develop an Industrial SWPPP as a requirement of coverage under the National 

Pollutant Discharge Elimination System (NPDES) Industrial Stormwater General Permit. Bayou Casotte 

Energy has developed a Spill Prevention, Containment, and Countermeasure Plan (SPCC Plan) to address 

hazardous material and petroleum spills during construction of both the onshore and offshore project 

facilities. The SPCC Plan describes preventative measures to minimize the likelihood of spills and leaks 

and mitigative measures to minimize impacts should a spill occur. Bayou Casotte Energy would develop 

a separate SPCC Plan after construction of the project to identify similar preventative measures that 

would be employed during operation of the LNG terminal and associated facilities. 

Some minor levels of soil contamination have been detected at the proposed LNG terminal site, 

and contaminated groundwater was also detected at multiple locations. Previous remediation activities 

were conducted at the site in an attempt to remove the contaminated soils resulting from the prior 

industrial operations, and significant exposure risk is not anticipated. We have also recommended that 

Bayou Casotte Energy develop a plan in consultation with the MDEQ and EPA regarding assessment, 

containment, and disposal of contaminated groundwater that might be encountered during any 

construction activities along with implementing its SPCC Plans to prevent or minimize the effects of 

spills, leaks, or other releases of hazardous substances on soil and water resources during construction and 

operations. 

Construction of the proposed LNG terminal slip would require excavation and dredging of about 

4.5 mcy of material. Of this total, approximately 1.0 mcy would be excavated above the water table using 

conventional earth moving equipment and used for fill, site leveling, and construction of the hurricane 

levee at the proposed terminal site. The remaining 3.5 mcy of material would be dredged from the slip, 

and maintenance dredging would require the removal of about 250,000 cubic yards of sediment on an 

annual basis. Bayou Casotte Energy indicates that its preferred alternative for disposal of both 

construction and maintenance dredge materials is placement at the EPA-designated Pascagoula Ocean 

Dredged Material Disposal Site (ODMDS), which is located offshore in the Gulf of Mexico south of Horn 

Island, with contribution to beneficial use sites as available. 

The proposed dredging activities associated with construction and maintenance of the terminal 

slip would have both direct and indirect impacts on aquatic resources. Potential adverse effects on 

aquatic resources include impairment of water quality, destruction of benthic habitat and communities, 

and direct and indirect impacts to fish and their prey species. However, we do not anticipate that 

dredging activities or associated disposal of sediments would result in significant adverse effects to 

aquatic resources, based on the results of the sampling and analyses conducted by Bayou Casotte Energy 

that are required pursuant to Section 103 of the Marine Protection, Research, and Sanctuaries Act 

(MPRSA). The Commission and Bayou Casotte Energy are proceeding under the assumption that the 

sediments dredged from the terminal site would be suitable for placement at the ODMDS. However, final 

agency approvals have not yet been obtained. 

No sole-source aquifer is located near the LNG terminal location. Though two private water 

supply wells are located within a 1-mile radius of the proposed LNG terminal site, both wells are located 

to the north along Bayou Casotte, upstream and up-gradient from the proposed Project. Potable water at 

the proposed LNG terminal would be supplied by an existing well at the Chevron Pascagoula Refinery, 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ES-4

and utility water would be supplied via municipal water mains. Construction and operation of the 

proposed Casotte Landing Project would not have a significant impact on groundwater resources in the 

Project area. 

The proposed interconnect spur pipeline would cross two drainage canals, and the proposed 

nonjurisdictional NGL pipeline would cross five perennial ditches and one perennial drainage canal. All 

surface waterbodies would be crossed using open-cut construction methods. To minimize impact on 

surface waters, Bayou Casotte Energy would implement the protective measures outlined in its Plan and 

Procedures, as described in this EIS, and the site-specific Stormwater Pollution Prevention Plan. 

Construction of the proposed LNG terminal and interconnect pipeline would affect about 

117 acres of low quality upland vegetation. The majority of the proposed terminal site consists of 

previously disturbed and developed industrial areas, and existing vegetation resources are generally 

fragmented and degraded by the presence of several invasive, exotic species. As construction of the 

proposed terminal facilities would result in a permanent conversion of vegetative cover, most impacts to 

vegetation resources would be permanent. Following construction, areas not containing new 

aboveground facilities at the proposed terminal site would be landscaped with gravel or turf grass. 

Disturbed upland vegetation along the pipeline route would be restored in accordance to Bayou Casotte 

Energy’s Plan, as described in this EIS, and allowed to revert to approximately pre-construction 

conditions. 

Construction of the proposed Project would directly affect a total of 146.9 acres of low to 

medium quality wetlands during construction. Of this total, approximately 119.3 acres would be 

permanently affected by development of the proposed terminal site. Meter station facilities associated 

with the proposed pipeline interconnects would permanently impact an additional 1.8 acres during 

operation. The nonjurisdictional NGL pipeline and associated meter station would impact 12.3 acres of 

wetlands during construction and 0.9 acres during operation. During construction, Bayou Casotte Energy 

would minimize construction-related impacts to wetlands and restore temporarily affected wetlands in 

accordance with the measures identified in its Procedures, as described in this EIS. Additionally, Bayou 

Casotte Energy has proposed to provide compensatory mitigation for unavoidable, permanent wetland 

impacts through mitigation banking, pursuant to the requirements of the Clean Water Act-Section 404 

authorizations; as outlined in its Joint Permit Application submitted to the COE. 

The onshore wildlife habitats in the vicinity of the proposed Project have been extensively 

modified by past development and industrial uses. The primary impact on wildlife associated with the 

proposed Project would be the clearing of upland and wetland habitats and temporary disturbances during 

construction. While some small, less mobile species would be injured or killed during construction, more 

mobile species would be displaced from the proposed terminal site permanently and temporarily from the 

pipeline construction right-of-way. Fish and aquatic species that reside in the waterbodies at the proposed 

terminal site would suffer mortality, but the existing, degraded quality of those waterbodies would 

preclude the loss of significant resources. Bayou Casotte Energy would minimize permanent impacts by 

constructing the proposed pipeline interconnects and NGL pipelines within or adjacent to other existing 

rights-of-way and industrial areas. As all construction would be conducted in accordance with the 

mitigation and restoration requirements described in Bayou Casotte Energy’s Plan and Procedures, as 

modified in this EIS, impacts to onshore wildlife habitat would be minimal. 

The estuarine benthic and aquatic habitats in the proposed Project area are reflective of a 

developed and previously disturbed setting. The benthic fauna are therefore primarily comprised of 

opportunistic and colonizing invertebrate species. Additionally, construction-related impacts to most 

marine fishes and other aquatic organisms would be temporary, as they would generally be able to avoid 

the work area. Additionally, turbidity modeling indicated that dredging activities would not result in 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ES-5

suspended sediment levels that exceed the existing, high background levels in Bayou Casotte. Further, 

we have included a recommendation that would require Bayou Casotte Energy to complete additional 

consultations and implement measures, as appropriate, to minimize the potential for entrainment and/or 

impingement of fish larvae and eggs of aquatic resources in association with ballast and cooling water 

withdrawals specific to the Casotte Landing LNG marine traffic shipping activities during operation. The 

EIS discusses potential impacts on shoreline and estuarine habitats if LNG were released from LNG ship 

cargo tanks while in transit. Because LNG would vaporize and is a cryogenic liquid, we conclude that the 

greatest threat to aquatic life from an LNG spill would be thermal stress. 

Essential fish habitat (EFH) for 18 individual species and the “billfish and highly migratory 

species group” has the potential to occur within the proposed Project area. Baseline data on existing EFH 

resources that occur within the proposed Project area is provided in the EFH Assessment included in this 

EIS. The proposed Project was sited and designed to avoid and minimize potential impacts to EFH, and 

we do not anticipate significant adverse effects to EFH or managed species in association with the 

proposed Project. We have also recommended that Bayou Casotte Energy develop a plan in consultation 

with NOAA Fisheries and other appropriate agencies to mitigate for those impacts that would occur to 

EFH from the construction and operation of the proposed LNG terminal, as well as from the LNG vessel 

traffic along the waterway from the territorial seas to the facility’s berthing. 

Based on consultations with FWS, NOAA Fisheries, and other agencies, we identified a total of 

26 federally listed endangered or threatened species that would potentially occur in the vicinity of the 

proposed Project, or along the waterway the LNG vessels would traffic along from the territorial seas to 

the proposed LNG terminal. Of those, 11 species do not occur in the proposed Project area or would not 

be affected by the construction and operation of the proposed LNG facilities. The proposed Project 

would potentially encompass and/or LNG marine traffic would potentially traverse habitat for the 

remaining 15 species. The 15 species include seven mammals (blue whale, fin whale, humpback whale, 

North Atlantic right whale, sei whale, sperm whale, and Florida manatee), five reptiles (green sea turtle, 

hawksbill sea turtle, Kemp’s ridley sea turtle, leatherback sea turtle, and loggerhead sea turtle), two birds 

(bald eagle and brown pelican), and one fish (Gulf sturgeon). We have determined that, with strict 

adherence to Bayou Casotte Energy’s proposed mitigation plans and our recommendations contained in 

this EIS, the proposed Project would have no effect or is not likely to adversely affect any federally listed 

endangered or threatened species. 

The majority of land within one mile of the proposed Project facilities consists of open water, 

wetlands, or lands occupied by various industrial facilities, and the land required for the proposed Project 

is all privately held. The nearest private residences to the proposed LNG terminal or along the LNG 

marine transit route are about 1.0 mile northwest of the site boundary, and the nearest special use area, 

Grand Bay National Estuary Research Reserve, is about 1.0 mile from the proposed terminal site. Two 

planned industrial developments have been identified in the immediate vicinity of the proposed LNG 

terminal site. Expansion of the Chevron Pascagoula Refinery is proposed within the existing boundary of 

the refinery and so adverse impacts are not expected. The other consists of a proposed LNG terminal 

whose application is currently being reviewed by the FERC. 

The most prominent visual features of the proposed Project would be three LNG storage tanks, 

each about 168 feet in height. However, these storage tanks and the other proposed terminal facilities 

would be consistent with the existing industrial facilities, and the proposed Project would not represent a 

significant visual impact. As Bayou Casotte is an existing industrial port, ship traffic there is common, 

and marine traffic associated with the proposed Project would not substantially change the visual 

character of the area. Likewise, the visual impact of the proposed pipeline interconnects and associated 

aboveground facilities, all of which are in direct proximity to existing industrial facilities, would not 

represent a significant change to the aesthetics of the existing landscape. 

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Construction of the proposed Project would result in a temporary increase in population, traffic, 

and the demand for temporary housing and public services, but these effects would be temporary and 

limited to the construction period. During operation, up to 170 LNG ships are expected to call at the 

proposed LNG terminal each year. Anticipated impacts on traffic are based on the assumption that the 

Coast Guard would establish a security zone for ships in transit to the LNG terminal. The exact size of 

the security zone has not been determined; however, assuming a similar security zone compared to other 

LNG terminals, the maximum delay expected due to the transit of an LNG vessel would be 1.5 hours. 

The realistic maximum delay an LNG ship transiting the channel could pose on a vessel transiting the 

Gulf Intracoastal Waterway (GIWW) would be about 30 minutes. As a result, the Casotte Landing LNG 

Project would have only minor impacts on marine traffic. In addition, the Coast Guard has made a 

preliminary determination that the waterways in the project area that would be used to transit to the 

proposed LNG facility may be suitable for the marine traffic with conditions. 

The proposed Project should not have an adverse effect on local property values, and would not 

disproportionately impact any minority or low-income neighborhoods. Construction and operation of the 

proposed Project would have a beneficial impact on local tax revenues and economies. The FERC 

believes the proposed project is practical, economical, and designed to meet energy infrastructure needs 

while minimizing environmental, safety, and engineering concerns. The FERC has not identified any 

high adverse human health or environmental effects that would be borne disproportionately by any 

minority or low-income group. 

The MDMR and the Pascagoula Special Management Area (SMA) are responsible for reviewing 

federal agency actions and activities to ensure that they are consistent with Mississippi’s Coastal 

Management Plan (CMP). The proposed Project is subject to a federal Coastal Zone Consistency Review 

because it would: 1) involve activities within the coastal zone; and 2) require several federal permits and 

approvals. Projects that require federal licenses or permits must draft a “consistency certification” to 

assure the proposed project meets the state’s CZM program standards. Bayou Casotte Energy has not 

completed the process for the federal consistency certification for the proposed LNG terminal facilities. 

We have recommended that Bayou Casotte Energy not be allowed to begin construction until it has 

received documentation confirming that the Project is consistent with the Mississippi’s CMP. 

Cultural resources surveys have been conducted for the proposed LNG terminal site and pipeline 

interconnect routes, and consultations with the Mississippi State Historic Preservation Officer were 

completed. Surveys, necessary treatment plans, and comments provided by the SHPO are in concurrence 

that no cultural or historically significant structures would be impacted by the proposed Project. 

Construction of the proposed Project would result in temporary and intermittent air emissions, but 

these emissions would not significantly affect air quality in the region. In order to provide a thorough 

evaluation of the potential impacts on air quality in the vicinity of the proposed project, Bayou Casotte 

Energy conducted a quantitative assessment of project air emissions. The assessment included air 

dispersion modeling analyses to predict off-site (i.e., ambient) concentrations in the vicinity of the project 

for PM10, sulfur dioxide (SO2), nitrogen dioxide (NO2), and carbon monoxide (CO) resulting from the 

proposed emissions associated with operation of the project for comparison to appropriate federal air 

quality standards. When the predicted impacts are added to available monitored background 

concentrations in the vicinity of the proposed project, none of the impacts would exceed the National 

Ambient Air Quality Standards (NAAQS). Further, the results of the modeling demonstrated that the 

project would not significantly impact the existing air quality at the Breton National Wildlife Refuge (a 

federal Class I area). 

During operation of the Casotte Landing LNG Project, air emissions from LNG marine traffic 

and other project-related vessels would occur along the entire waterway from the territorial sea to the ship 

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berth. The emissions to any one localized area during ship transit would be temporary and transient and 

would be occurring at distances allowing for considerable dispersion before reaching any sensitive 

receptors; therefore, air emissions from ship transit are not expected to result in a significant impact on air 

quality. 

Bayou Casotte Energy would minimize air emissions from the proposed stationary sources 

through the use of clean fuel (natural gas and low sulfur diesel oil) and the employment of BMPs for 

operation and maintenance procedures. 

Most of the predicted PM10 emissions are associated with fugitive dust produced during 

construction of the LNG terminal facilities and associated pipeline. Fugitive dust could have an impact in 

the immediate vicinity of construction activity and would cease once construction in a particular area is 

complete. Measures Bayou Casotte Energy would implement to reduce dust emissions include applying 

water, using BMPs, and scheduling construction operations to avoid concurrent operations by larger 

emission sources when feasible. We have recommended that Bayou Casotte Energy include these 

measures and additional mitigation measures to further reduce emissions in a Fugitive Dust Control Plan. 

Bayou Casotte Energy conducted a joint modeling analysis to evaluate cumulative impacts of the 

Bayou Casotte LNG Project and the Clean Energy LNG Project, incorporating existing emission sources 

and all reasonably foreseeable future sources (Bayou Casotte LNG Project, the Clean Energy LNG 

Project, and Pascagoula Refinery Expansion). The results indicate that none of the combined impacts 

would exceed the NAAQS. Also, the impacts from the combined projects would not significantly impact 

the existing air quality at the Breton National Wildlife Refuge (a federal Class I area). 

Noise receptors in the immediate vicinity of construction activities at the proposed terminal site 

and along the pipeline interconnect route would experience an increase in noise levels, but such increases 

would be localized, temporary, and primarily limited to daylight hours. Noise associated with dredging 

operations at the proposed terminal site would be the most noticeable and would occur up to 24 hours a 

day for a period of about 6 months. However, the predicted noise levels at the nearest noise sensitive area 

(NSA) during excavation, dredging, and pile driving activities, would be below existing ambient noise 

levels and the FERC’s threshold of a day-night sound level (Ldn) of 55 decibels on the A-weighted scale. 

Although construction activities may be audible during relatively quiet periods, noise-related impacts are 

expected to be minimal and no mitigation would be required. Activities at the proposed LNG terminal 

would generate noise on a continuous basis during operations. However, noise attenuation computer 

modeling indicates that the predicted noise levels attributable to operations would not result in significant 

effects on the NSAs nearest to that facility. Additionally, we have included recommendations for 

completion of post-construction noise surveys and implementation of additional mitigation measures, if 

required, to ensure that actual noise levels resulting from Project operations would not exceed significant 

or existing levels. 

Noise generated by LNG marine traffic along the waterway from the territorial sea to the 

proposed LNG terminal would be similar to noise from other large ships using the waterway. Underwater 

noise would cause a local and temporary avoidance behavior in fish but would not result in significant 

adverse impacts. Above-water noise associated with the LNG vessels would not result in significant 

impacts on environmental resources. 

 We evaluated the safety of both the proposed facilities and the related LNG marine transit 

through the Mississippi Sound and Bayou Casotte Channel. As part of our evaluation, we performed a 

cryogenic design and technical review of the proposed terminal design and safety systems. We identified 

several specific areas of concern and included recommendations to address these concerns. 

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Thermal radiation and flammable vapor hazard distances were calculated for an accident or an 

attack on a LNG carrier. For 1.0-, 2.5-, 3.0-, and 3.9-meter-diameter holes in an LNG cargo tank, we 

estimated distances to range from 2,164 to 5,220 feet for a thermal radiation level of 1,600 British thermal 

units per hour per foot per hour, the level which is hazardous to unprotected persons located outdoors. 

Based on the analysis of a 1.0-meter-diameter hole, an unignited release would result in an estimated pool 

radius of 421 feet. The unignited vapor cloud would extend to 9,776 feet to the lower flammability limit 

(LFL) and 14,377 feet to one-half the LFL. Flammable vapor dispersion for larger holes was not 

performed because, realistically, the cloud would not even extend to the maximum distance for a 

1.0-meter-diameter hole before encountering an ignition source. However, the evaluation of safety is 

more than an exercise in calculating the consequences of worst case scenarios. Rather, it is a 

determination of the acceptability of risk which considers: the probability of events, the effect of 

mitigation, and the consequences of events. Based on the extensive operational experience of LNG 

shipping, the structural design of a LNG carrier, and the operational controls that may be imposed by the 

Coast Guard and the local pilots, the likelihood of a cargo containment failure and subsequent LNG spill 

from a vessel casualty – collision, grounding, or allision – is highly unlikely. For similar reasons, an 

accident involving the onshore LNG import terminal is unlikely to affect the public. As a result, the risk 

to the public from accidental causes should not be considered significant. 

As part of our marine safety analysis, we considered how vessel security requirements for LNG 

carriers calling on the proposed LNG terminal might affect other ship and boat traffic in Pascagoula Bar, 

Horn Island Pass, Lower Pascagoula, and Bayou Casotte Channels. Based on the Coast Guard’s 

longstanding experience in controlling the movements of dangerous cargo vessels in the area and LNG 

carriers in other ports, potential impacts can be evaluated for several general security requirements: 

1) moving safety zone for inbound and outbound LNG marine traffic; 2) one-way vessel traffic during 

LNG marine transit; and 3) security zone around a moored LNG carrier. The moving safety zone, the 

moored vessel security zone at the terminal, and one-way traffic would affect other commercial and 

recreational traffic using these waterways. Based on a navigation simulation study conducted by Moffatt 

& Nichol, International on behalf of Bayou Casotte Energy, the addition of 170 LNG carriers per year 

would have minor effects on other shipping operations in the Port of Pascagoula. If both of the proposed 

LNG terminal facilities proposed for the area and currently under our review were constructed, the 

increased traffic would average almost two vessel transits per day. Other shipping activities would be 

moderately affected by the increase in traffic; however, based on the relatively low volume of existing 

shipping activity in the berthing area to the territorial sea, the impact is not expected to be substantial. 

The extent of the impact on recreational boaters would depend on the number of boats in the 

Project area when LNG carriers call on the LNG terminal. The impact would also depend on other 

variables such as the size of the Coast Guard-imposed safety and security zones and the width of the 

channel at the point where a boat encounters the LNG carrier. To minimize potential impacts on other 

marine traffic, if the Coast Guard issues a LOR finding the waterway to be suitable for LNG vessel traffic 

with conditions, it may use a program of announcements to give advance notice of the schedule of each 

moving safety and moored vessel security zones and may restrict LNG marine transit times to periods less 

likely to affect recreational boaters. 

Unlike accidental causes, historical experience provides little guidance in estimating the 

probability of a terrorist attack on a LNG carrier or onshore storage facility. For an LNG import terminal 

proposal that would involve having a large volume of energy transported and stored near populated areas, 

the perceived threat of a terrorist attack is a primary concern of the local population and requires that 

resources be directed to mitigate possible attack paths. While the risks associated with the transportation 

of any hazardous cargo can never be entirely eliminated, they can be managed. 

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The Coast Guard has issued a preliminary evaluation, in a letter to the FERC on 

September 5, 2006, of Bayou Casotte Energy’s Waterway Suitability Assessment (WSA). In accordance 

with guidance promulgated in Coast Guard Navigation and Vessel Inspection Circular (NVIC05-05), 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. As a result of this review, in its 

Waterway Suitability Report (WSR) the Coast Guard made a preliminary determination that the 

Pascagoula Bar, Horn Island Pass, Lower Pascagoula, and Bayou Casotte Channels may be suitable for 

the LNG marine traffic associated with this project. With the completion of this final EIS, the Coast 

Guard will complete its review and issue an LOR with conditions to address the suitability of the 

waterways for LNG transport. 

The Coast Guard’s LNG Vessel Transit Management Plan would be developed in conjunction 

with state and local law enforcement and emergency response communities. Under 33 CFR 165 for LNG 

vessels in transit and while docked, the Coast Guard, as conditions of the LOR, may establish a moving 

safety zone during LNG vessels’ transit of the waterway, require daylight transit and one-way LNG vessel 

traffic on the waterway, and establish a moored vessel security zone. Only personnel or vessels 

authorized by the Captain of the Port are permitted within these zones. 

Section 311 of the Energy Policy Act of 2005 stipulates that the FERC must require the LNG 

operator to develop an Emergency Response Plan that includes a Cost-Sharing Plan before any final 

approval to begin construction. The Cost-Sharing Plan shall include a description of any direct cost 

reimbursements to any state and local agencies with responsibility for security and safety at the LNG 

terminal and near vessels that serve the facility. 

ALTERNATIVES CONSIDERED 

The EIS addresses alternatives to the proposed actions before both the FERC and the Coast 

Guard. The proposed action before the FERC is to consider issuing to Bayou Casotte Energy a Section 3 

authorization for the LNG import facilities. The proposed action before the Coast Guard is to issue a LOR 

finding the waterway suitable for LNG marine traffic, with conditions, including: 1) establishment of a 

moving safety zone during LNG vessels’ transit of the waterway, including the requirements for daylight 

transit and one way LNG vessel traffic on the waterway, and for another safety zone around the LNG 

facility when the LNG vessels are moored; 2) the applicant shall conduct an annual review of its 

Waterway Suitability Assessment to evaluate if any conditions in the waterway have changed that would 

require issuance of a new LOR and submit such annual review to the COTP for his/her review and 

issuance of a new LOR if required; 3) the requirement that LNG vessels must navigate the waterway from 

the outer sea buoy to the berthing areas with Pascagoula pilots onboard; 4) the requirement that tug 

assistance be provided as deemed necessary by the Pascagoula pilots; 5) the requirement that prior to 

crossing the Gulf Intracoastal Waterway, all LNG traffic will be required to make a SECURITE 

broadcast: 6) implementation of a Coast Guard approved LNG Vessel Transit Management Plan, and; 7) 

availability of Coast Guard resources to implement the above security measures. 

As an alternative to the proposed action, we evaluated the no action or postponed action 

alternatives, system alternatives, LNG terminal site alternatives, LNG terminal design alternatives, 

pipeline interconnect alternatives, and dredge material placement alternatives. While the no action or 

postponed action alternative would eliminate the environmental impacts identified in this EIS, the Project 

objectives of providing a new source of natural gas to markets that can be accessed through the proposed 

pipeline interconnects would not be met. 

For the Coast Guard’s proposed action, the no action alternative would be issuance of Coast 

Guard LOR finding the waterway not suitable for LNG marine traffic. Similar to the no action alternative 

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of the FERC, the no action alternative for the Coast Guard would avoid any Project related environmental 

effects. However, the no action alternative would also prevent LNG carriers from delivering LNG to the 

proposed import terminal, and the objectives of the proposed Project would not be met. Reasonable 

alternatives to the Coast Guard action of issuing an LOR with conditions include: 1) postponing the 

issuance of a Coast Guard LOR pending further analysis and study; and 2) issuance of a Coast Guard 

LOR finding the waterway suitable for LNG vessel traffic without conditions. 

If the Coast Guard postpones issuance of an LOR pending further analysis and study, the effect 

would likely be similar to the FERC postponing its action. That is, although it is speculative to predict 

the resulting effects, postponing issuance of an LOR would lead Bayou Casotte Energy to delay the 

Project. A reasonable alternative to the Coast Guard action of issuing a LOR that finds the waterway 

suitable for LNG marine traffic with the conditions referenced previously, is to issue a LOR finding the 

waterway suitable for LNG vessel traffic without conditions. As described in its letter to the FERC dated 

September 5, 2006, the Coast Guard has issued a preliminary determination of the waterway, subject to 

the evaluation of several conditions before a final suitability evaluation can be made. The Coast Guard 

will only issue a LOR following the completion of the NEPA evaluation. 

Our analysis included an evaluation of both existing onshore and offshore LNG terminals, as well 

as existing natural gas pipeline systems. In addition, we also analyzed various recently approved and 

proposed projects, including the construction of an offshore terminal, to meet the objectives of the 

proposed Casotte Landing Project. Pipeline system alternatives would not provide new, non-domestic 

sources of natural gas, and therefore be unable to meet the objectives of the proposed Project. Relative to 

the proposed Project, it is unclear how efficiently or effectively, the other existing, approved, and 

proposed onshore LNG terminal projects would satisfy the objectives of the proposed Casotte Landing 

Project. Further, we do not consider that any of the offshore LNG terminal technologies represent an 

environmentally preferable or technically and economically feasible and practical alternative to the 

proposed Project. 

The proximity of the proposed terminal site to the Chevron Pascagoula Refinery would provide 

numerous synergies and environmental benefits, including use of existing services for security and safety, 

minimization of landowner impacts, and use of waste heat from the Refinery to accomplish LNG 

vaporization. We also considered that other potential locations would be unlikely to satisfy the proposed 

Project objectives. Therefore, we did not did not conduct a detailed regional screening analysis to 

identify alternative terminal locations. However, we did consider local siting alternatives for the 

proposed LNG terminal. We also considered LNG terminal design alternatives, including four terminal 

slip configuration alternatives, five vaporization technology alternatives, and electrical power system 

alternatives, as well as route alternatives for the proposed pipeline interconnect spur. However, relative to 

the proposed Project none of the alternatives evaluated were considered environmentally preferable 

and/or technically and economically feasible. We also considered LNG terminal design alternatives, 

including four terminal slip configuration alternatives, five vaporization technology alternatives, and 

electrical power system alternatives, as well as route alternatives for the proposed pipeline interconnect 

spur. However, relative to the proposed Project none of the alternatives evaluated were considered 

environmentally preferable and/or technically and economically feasible. In, conclusion, we have 

determined that the proposed project is the preferred alternative that can meet the project objectives. 

We evaluated four general alternatives for placement of the 3.5 mcy of initial and 250,000 yd3

 of 

annual maintenance dredge material that would result from construction and operation of the proposed 

Project. Bayou Casotte Energy indicates that its preferred alternative for placement of both construction 

and maintenance dredge materials is placement at the ODMDS, with contribution to beneficial use sites as 

available. Pending receipt of the required approvals under Section 103 of the MPRSA, we do not 

consider any of the dredge material placement alternatives evaluated to represent a technically or 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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environmentally preferable alternative to Bayou Casotte Energy’s preferred dredged material placement 

plan. 

PUBLIC INVOLVEMENT AND AREAS OF CONCERN 

On February 10, 2005, Bayou Casotte Energy filed a request with the FERC to implement the 

Commission’s Pre-filing Process for the Casotte Landing Project. At that time, Bayou Casotte Energy 

was in the preliminary design stage of the proposed Project and no formal application had been filed with 

the FERC. On March 2, 2005, the FERC granted Bayou Casotte Energy’s request and established a prefiling docket number (PF05-9-000) to place information filed by Bayou Casotte Energy and related 

documents issued by the FERC into the public record. The purpose of the Pre-filing Process is to 

encourage the early involvement of interested stakeholders, facilitate interagency cooperation, and 

identify and attempt to resolve issues before an application is filed with the FERC. 

The FERC formally introduced the Pre-filing Process to various Project stakeholders by issuing a 

notice titled Pre-Filing Process Review: Casotte Landing LNG Project (Docket No. PF05-9-000). This 

Pre-filing Notice, issued on March 11, 2005, was sent to interested parties including federal, state, and 

local government agencies; elected officials; environmental and public interest groups; Native American 

tribes; local libraries and newspapers; and landowners within 0.5 mile of the proposed LNG terminal. 

On April 7, 2005, the FERC issued a Notice of Intent to Prepare an Environmental Impact 

Statement for the Proposed Casotte Landing Project, and Request for Comments on Environmental 

Issues, and Notice of Public Scoping Meeting, and Site Visit for Both Casotte Landing LNG Project and 

LNG Clean Energy Project (NOI). The NOI was sent to many of the same interested parties as the first 

notice. Both of these notices encouraged Project stakeholders or interested parties to provide input on 

environmental issues that should addressed during the environmental review process. The NOI 

specifically requested comments before May 6, 2005. In total, five comment letters were received by the 

FERC in response to the Pre-filing Notice and the NOI. 

On April 20, 2005, the FERC staff conducted an inspection of the proposed terminal site that was 

open to the public. Later that evening, the FERC conducted a public scoping meeting in Pascagoula, 

Mississippi, to provide an opportunity for the general public to learn more about the proposed Project and 

to participate in our analysis by commenting on issues to be included in the EIS. Nine individuals 

provided comments at that meeting, primarily regarding the impacts of the proposed Project on the local 

socioeconomic conditions and safety. A transcript of these comments is part of the public record for the 

Casotte Landing Project. 

On October 31, 2005, the FERC issued a Notice of Application (Docket No. CP05-420-000), 

which announced the filing of an application by Bayou Casotte Energy and a final opportunity to submit 

comments. The FERC’s comment period closed on January 30, 2006. In total, 7 comment letters were 

received by the FERC in response to these notices. 

The Coast Guard published a notice in the Federal Register on November 17, 2005 stating that it 

was preparing a letter of recommendation as to the suitability of the Pascagoula Bar, Horn Island Pass, 

Lower Pascagoula, and Bayou Casotte Channels for LNG marine traffic. On December 7, 2005, the 

Coast Guard conducted a public meeting in Pascagoula to provide an opportunity for the general public to 

provide comments on waterway suitability and maritime safety and security aspects of the proposed LNG 

facilities. Four people commented at the meeting and four comments were received in writing following 

the meeting. The majority of the comments concerned safety and security of the port, safety and security 

of the LNG carriers, and impacts to recreational boaters and commercial fishing vessels. A transcript of 

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these comments and the Coast Guard Response to them is part of the public record for the Casotte 

Landing Project. 

On April 5, 2006, FERC staff conducted a cryogenic design and technical conference with Bayou 

Casotte Energy personnel in Mobile, Alabama to discuss design and engineering aspects of the Casotte 

Landing LNG Project. The meeting was limited to existing parties to the proceeding (i.e., anyone who 

specifically requested to intervene as a party). Attendees included agency representatives (U.S. 

Department of Transportation Pipeline and Hazardous Materials Safety Administration and Coast Guard), 

industry representatives, and other interested parties. 

In addition to the public notice and scoping process discussed above, the FERC conducted agency 

consultations and participated in interagency meetings to identify issues that should be addressed in this 

EIS. These activities included participation in interagency meetings in Pascagoula, Mississippi, on 

April 20, and August 4, 2005, to discuss the proposed Project and its associated environmental review 

process with other key federal and state agencies. These agencies included the COE; Coast Guard; 

NOAA Fisheries; FWS; DOT; Mississippi Department of Environmental Quality (MDEQ); MDMR; and 

the Gulf States Marine Fisheries Commission. 

The FERC prepared a draft EIS for the Casotte Landing LNG Project and issued a Notice of 

Availability (NOA) of the draft EIS on May 19, 2006. In accordance with Council on Environmental 

Quality’s (CEQ’s) regulations implementing NEPA, the NOA established a public comment period 

ending on July 10, 2006, described procedures for filing comments on the draft EIS, and announced the 

time, date, and location of the public comment meeting. The NOA also indicated that additional project 

information could be obtained from the Commission’s Office of External Affairs and on the FERC’s 

Internet website. A formal notice was also published in the Federal Register on May 25, 2006, indicating 

that the draft EIS was available and had been mailed to individuals and organizations on the mailing list 

prepared for the project. 

The FERC mailed approximately 430 copies of the draft EIS to Federal, state, and local agencies, 

elected officials, Native American groups, newspapers, public libraries, intervenors to the FERC's 

proceeding, and other interested parties (i.e., landowners, other individuals, and environmental groups 

who requested a copy of the draft EIS). The FERC also conducted a public comment meeting in 

Pascagoula, Mississippi on June 22, 2006. A total of four people provided comments at the meeting. In 

addition, the FERC received six comment letters in response to the draft EIS. The FERC has responded 

to these comments in the final EIS. 

MAJOR CONCLUSIONS 

As part of our review, we developed measures we believe would appropriately and reasonably 

avoid, minimize, or mitigate for environmental impacts resulting from the construction and operation of 

the proposed Project. We are recommending that these mitigation measures be attached as conditions to 

any authorization issued by the Commission. We conclude that if the Project is found to be in the public 

interest and is constructed and operated in accordance with Bayou Casotte Energy’s proposed mitigation 

and our recommended mitigation measures, the proposed facilities would have limited adverse impacts. 

The primary reasons for our decision are: 

• the Project would make use of a previously disturbed site adjacent to an existing 

industrial site; 

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• proximity of the proposed terminal site to the Chevron Pascagoula Refinery would facilitate 

use of waste heat from the Refinery to accomplish LNG vaporization, providing significant 

environmental benefits; 

• Bayou Casotte Energy would implement the its Plan and Procedures, as described in this EIS, 

to mitigate impacts on soils, wetlands, and waterbodies; 

• Bayou Casotte Energy would implement mitigation plans for permanent wetland impacts; 

• all applicable federal, state, and local permits and authorizations would be obtained by Bayou 

Casotte Energy prior to initiating activities requiring such permits and authorizations; 

• the safety features that would be incorporated into the design and operation of the LNG 

import terminal and the LNG marine traffic; 

• the operational controls that may be imposed by the Coast Guard to direct the movement of 

LNG marine traffic, and the security provisions to deter attacks by potential terrorists; and 

• the environmental inspection and mitigation monitoring program that would ensure 

compliance with all mitigation measures that become conditions of any FERC authorization. 

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1-1

1.0 INTRODUCTION 

On September 30, 2005, Bayou Casotte Energy LLC, a subsidiary of Chevron U.S.A. Inc. 

(Chevron), filed its application with the Federal Energy Regulatory Commission (FERC or Commission) 

under Section 3(a) of the Natural Gas Act (NGA). The application was noticed in the Federal Register on 

October 31, 2005. In Docket No CP05-420-000, Bayou Casotte Energy LLC seeks authorization to site, 

construct, and operate a liquefied natural gas (LNG) terminal and ancillary facilities to connect the 

proposed LNG terminal to existing interstate gas transmission facilities near Pascagoula, Mississippi. 

Hereafter, Bayou Casotte Energy LLC is referred to as Bayou Casotte Energy, and the proposed Project, 

including the LNG terminal and pipeline components, is referred to as the Casotte Landing Project or 

Project. 

Bayou Casotte Energy’s proposed facilities would send out a nominal 1.3 billion cubic feet per 

day (Bcfd) of imported natural gas to the United States market. In order to provide LNG import, storage, 

and pipeline transportation services, Bayou Casotte Energy requests Commission authorization to 

construct, install, and operate an LNG terminal and associated natural gas pipeline facilities. 

The LNG terminal facilities would include: 

• a ship unloading facility with berthing capabilities for one LNG carrier ship with cargo 

capacities up to 200,000 cubic meters (m3

) 1;

• three 160,000 m3

 full containment LNG storage tanks; 

• a closed-loop intermediate fluid vaporization system capable of a nominal sendout capacity 

of 1.3 Bcfd; and 

• various ancillary facilities, including administrative offices, LNG control center, and 

guardhouse. 

The natural gas pipeline facilities would include: 

• five pipeline interconnects originating from a 1.5-mile-long, 36-inch-diameter spur; and 

• associated pipeline support facilities, including metering facilities at each interconnect with 

the existing pipeline systems. 

In addition to the LNG terminal and natural gas pipeline facilities, the Casotte Landing Project 

would require construction of facilities that do not fall under the Commission’s jurisdiction. These 

facilities include the relocation of two crude oil berths, a main power station and four electric substations, 

a heated wastewater delivery and cool water return system, and a natural gas liquids (NGL) extraction 

system and pipeline. These facilities are addressed further in Section 2.2. 

 

1

 Bayou Casotte Energy indicates that the existing Bayou Casotte shipping channel and associated navigational aids 

are currently only sufficient to accept LNG carriers up to approximately 160,000 m3

 capacity, but the Casotte 

Landing Project as proposed has been designed with the flexibility to accommodate larger LNG carriers should the 

channel be modified at a future date to enable their passage. 

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1-2

1.1 PROJECT PURPOSE AND NEED 

Bayou Casotte Energy proposes to provide an additional source of firm, long-term, and 

competitively priced natural gas to the southeast and the broader United States markets by accessing 

natural gas reserves throughout the world. For the Project to be viable and to satisfy its objectives, Bayou 

Casotte Energy indicated that the Project facilities must satisfy the following specific attributes: 

• be technically and economically feasible, and practicable; 

• access gas markets primarily in the southeastern United States, as well as the Mid-Atlantic 

and New England regions, through pipeline interconnects with existing intra- and interstate 

pipeline infrastructure; 

• ensure that LNG marine traffic can safely arrive to the facility, which requires a Letter of 

Recommendation (LOR) from the Coast Guard determining the waterway to be suitable for 

LNG marine traffic; 

• provide vaporization facilities to accommodate the send-out of natural gas all year at a 

nominal rate of approximately 1.3 bcfd; 

• provide LNG storage facilities with a combined capacity of at least 480,000 m3

; 

• provide facilities needed to receive and unload a range of LNG carriers from approximately 

125,000 m3

 to 200,000 m3 capacity, while making use of an existing 42-foot-deep shipping 

channel; 

• start-up terminal operations by 2010; 

• be located proximal to existing NGL infrastructure and markets for the sale of associated 

liquids; 

• provide synergies with other existing Chevron owned businesses; and 

• provide Bayou Casotte Energy sufficient control and proprietary rights of operation to ensure 

operability for a 25- to 30-year project life. 

Energy demand in the southeast and the United States has been growing and continues to increase 

steadily. The U.S. Department of Energy’s (DOE’s) Annual Energy Outlook 2006, estimates that total 

energy consumption in the U.S. will increase from 99.7 quadrillion British Thermal Units (BTU) per year 

in 2004 to 127.0 quadrillion BTU per year in 2025, representing an annualized increase of 1.2 percent 

(EIA 2006). Although this energy will be obtained from a variety of sources (coal, petroleum, 

hydropower and other renewable sources), natural gas usage will represent about 22 percent of all energy 

consumption by 2025. To maintain pace with growing energy demands, the EIA anticipates that 

consumption of natural gas in the United States will grow from 22.4 trillion cubic feet (Tcf) per year in 

2004 to 27.0 TCF in 2025. In the southeastern U.S. (Alabama, Florida, Louisiana, Mississippi, and 

Georgia) natural gas consumption is projected to increase from 4.0 Tcf per year in 2003 to 4.7 Tcf per 

year in 2025, an annualized increase of 2.4 percent (EIA 2005). The growth in natural gas demand is 

driven primarily by increased use of natural gas for electricity generation and industrial applications, 

which together account for 62 percent of the projected demand growth from 2004 to 2025 (EIA 2006). 

The natural gas supply in the United States currently comes from three basic sources: domestic 

production, pipeline imports from Canada and Mexico, and imports of LNG. Domestic production is 

projected to increase from about 18.5 Tcf in 2004 to about 21.6 Tcf in 2019, before beginning a gradual 

decline to 20.8 Tcf by 2030 (EIA 2006). Even though some moderate growth in domestic production is 

anticipated over the near term, this growth would not keep pace with increasing demand. Likewise, net 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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pipeline imports of natural gas from Canada and Mexico are also expected to continue to decline as a 

function of depletion and growth in Canada’s domestic consumption (EIA 2006). For these reasons, LNG 

imports will become increasingly important sources of natural gas for the United States. 

LNG is natural gas that has been cooled to about minus 260 degrees Fahrenheit (°F) for shipment 

and storage as a liquid. LNG is more compact than the gaseous equivalent, with a volumetric difference 

of approximately 610 to 1. LNG can be transported long distances across oceans using specially designed 

ships, thus allowing access to stranded reserves of natural gas that cannot be transported by conventional 

pipelines. There are currently five operational LNG import terminals in the United States (see 

Section 3.3), but more than 35 new LNG terminals have been proposed or planned for the United States. 

Additional terminals that would serve United States markets have also been proposed to Canadian, 

Mexican, and Bahamian regulatory authorities. A number of factors are contributing to interest in 

increasing the level of United States imports of LNG (currently there are over 30 new LNG terminals 

under consideration), including higher domestic natural gas costs; the leveling-off of domestic gas 

supplies; and technological advances in liquefying, shipping, storing, and regasifying, which have 

reduced the cost of transporting and importing LNG (Gaul and Young 2003). Total net imports of LNG 

to the United States are projected to increase from 0.6 Tcf in 2004 to 4.1 Tcf in 2025 (EIA 2006). 

However, the EIA expects that total LNG imports would be even higher under some alternative scenarios, 

particularly those that assume higher natural gas prices. 

1.2 PURPOSE AND SCOPE OF THIS STATEMENT 

The FERC is the federal agency responsible for authorizing applications to construct and operate 

onshore LNG import and interstate natural gas transmission facilities. As such, the FERC is the lead 

federal agency for the preparation of this Environmental Impact Statement (EIS) in compliance with the 

requirements of the National Environmental Policy Act of 1969 (NEPA), the Council on Environmental 

Quality (CEQ) regulations for implementing NEPA (40 Code of Federal Regulations [CFR] 1500-1508), 

and the FERC regulations implementing NEPA (18 CFR 380). 

The U.S. Army Corps of Engineers (COE); U.S. Department of Homeland Security, U.S. Coast 

Guard (Coast Guard); U.S. Department of the Interior, Fish and Wildlife Service (FWS); U.S. Department 

of Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries Service 

(NOAA Fisheries); U.S. Department of Transportation (DOT); U.S. Environmental Protection Agency 

(EPA); and the Mississippi Department of Marine Resources (MDMR) are cooperating agencies for the 

development of this EIS. A cooperating agency has jurisdiction by law or special expertise with respect 

to environmental impacts involved with the proposal, and is involved in the NEPA analysis. Other state 

and local agencies that have been coordinated with in the preparation of this EIS include Mississippi 

Department of Environmental Quality (MDEQ), Gulf States Marine Fisheries Commission and Jackson 

County Port Authority. 

This document was prepared to respond to public scoping comments received on the draft EIS. 

The distribution list for the draft EIS is provided in Appendix A. 

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Our principal purposes in preparing this EIS are to:2

• identify and assess potential impacts on the natural and human environment that would result 

from the implementation of the proposed actions, including the Coast Guard’s proposed 

action of issuing a LOR finding the waterway to be suitable for LNG vessel traffic with 

conditions referenced in Section 2.0; 

• describe and evaluate reasonable alternatives to the proposed actions that would avoid or 

minimize adverse effects on the human environment; 

• identify and recommend specific mitigation measures, as necessary, to minimize the 

environmental impacts; and 

• facilitate public involvement in identifying the significant environmental impacts. 

The FERC will consider the findings of the final EIS in its determination of whether the Project 

should be approved. A final approval will only be granted if, after a consideration of both environmental 

and non-environmental issues, the FERC finds that the proposed Project is in the public interest. The 

environmental impact assessment and mitigation development discussed herein will be important factors 

in this final determination. The Coast Guard will determine whether to issue an LOR finding the 

waterway to be suitable for LNG marine traffic with conditions (see section 2.0). 

Our analysis in this EIS focuses on the facilities that are under the FERC’s jurisdiction (i.e., the 

LNG import terminal and pipeline interconnects proposed to be constructed by Bayou Casotte Energy) as 

well as the nonjurisdictional facilities that are integrally related to the development of the Project (i.e., 

crude berth relocations, and including the LNG vessel transit waterway from territorial seas to the LNG 

facility’s berthing area, electric power station and substations, heated wastewater delivery and cool water 

return system, and NGL extraction system and pipeline). 

The topics addressed in this EIS include geology; soils and sediments; water use and quality; 

wetlands; vegetation; wildlife; fish and marine invertebrates; threatened, endangered, and special-status 

species; land use, recreation, and visual resources; cultural resources; socioeconomics and traffic; air 

quality and noise; reliability and safety; cumulative effects; and alternatives. The EIS describes the 

affected environment as it currently exists, discusses the environmental consequences of the proposed 

Project, and compares the Project’s potential impact to that of alternatives. The EIS also presents our 

conclusions and recommended mitigation measures. 

Currently, there is one other proposal to build an LNG import facility along Bayou Casotte in the 

Pascagoula area. The LNG Clean Energy Project (FERC Docket Nos. PF05-5-000 and CP06-12-000), as 

proposed by Gulf LNG Energy, LLC and Gulf LNG Pipeline, LLC (collectively referred to hereafter as 

Gulf LNG), would be located south of the Casotte Landing Project. Although these two LNG projects are 

on similar schedules, the FERC is preparing a separate EIS for each of the projects. The Commission 

does not consider the other proposed facility to be a mutually exclusive alternative to the Casotte Landing 

Project; rather as a new source that would help satisfy the increasing regional and national demand for 

natural gas (see Section 3.3). In addition, the FERC has a regulatory responsibility to act on each of the 

projects that are filed with it in a timely manner. Linking the environmental analyses of both LNG 

projects into a single EIS would result in delaying action on one or both of the projects based on 

insufficient data or unresolved issues associated with just one of the projects. The potential cumulative 

 

2 The pronouns “we,” “us,” and “our” refer to the environmental staff of the Office of Energy Projects (OEP), part 

of the FERC staff.

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environmental effects of the two proposed LNG projects, as well as other past, present, and reasonably 

foreseeable projects and activities, are addressed in this EIS (see Section 4.13), as well as that prepared 

for the other project. 

1.3 PERMITS, APPROVALS, AND REGULATORY REQUIREMENTS 

As the lead federal agency for the Casotte Landing Project, the FERC is required to comply with 

Section 7 of the Endangered Species Act of 1973 (ESA), the Magnuson-Stevens Fishery Conservation 

and Management Act (MSA), Section 106 of the National Historic Preservation Act (NHPA), and 

Section 307 of the Coastal Zone Management Act of 1972 (CZMA). Each of these statutes has been 

taken into account in the preparation of this document. 

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 United States Code (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 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. 

As required by its regulations, the Coast Guard is responsible for issuing a Letter of 

Recommendation (LOR) as to the suitability of the waterway for LNG marine traffic. The LOR would be 

based on the following items: 

• density and character of marine traffic; 

• locks, bridges, or other manmade obstruction in the waterway; 

• environmental impacts from LNG vessel traffic in the waterway from the territorial seas to 

the LNG facility’s berthing areas; and 

• the following factors adjacent to the facility: 

a. depth of water; 

b. tidal range; 

c. protection from high seas; 

d. natural hazards, including reefs, rocks, and sandbars; 

e. underwater pipes and cables; and 

f. distance of berthed vessels from the channel and the width of the channel. 

In accordance with Title 33 CFR Part 127.007, each applicant must submit a Letter of Intent 

(LOI) to the local Captain of the Port (COTP) to begin the LOR process. On June 14, 2005, the Coast 

Guard issued 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 this 

NVIC 05-05 is to provide Coast Guard COTP/Federal Maritime Security 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, will also take completely into account 

maritime security implications. In accordance with this guidance, each LNG project applicant is to 

submit a Waterway Suitability Assessment (WSA) to the cognizant COTP. The WSA is to address the 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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transportation of LNG from the LNG tanker’s entrance into U.S. territorial seas, through its transit to and 

from the LNG receiving facility, including operations at the 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. 

Section 7 of the ESA, as amended, states that any project authorized, funded, or conducted by a 

federal agency (e.g., FERC) should not “jeopardize the continued existence of any endangered species or 

threatened species or result in the destruction or adverse modification of habitat of such species which is 

determined...to be critical” (16 United States Code [USC] § 1536(a)(2)). The FERC, or the applicant as a 

non-federal party, is required to consult with the FWS and NOAA Fisheries to determine whether any 

federally listed or proposed endangered or threatened species or their designated critical habitat occur in 

the vicinity of the proposed Project, or along the waterway from the territorial seas used by the LNG 

marine traffic to access the berthing area. If, upon review of existing data or data provided by the 

applicant, the FERC determines that these species or habitats may be affected by the proposed Project, the 

FERC is required to prepare a biological assessment to identify the nature and extent of adverse impact, 

and to recommend measures that would avoid the habitat and/or species, or would reduce potential 

impacts to acceptable levels. Section 4.6.1 of this EIS provides additional discussion on the status of the 

ESA review for the proposed Project. 

The MSA, as amended by the Sustainable Fisheries Act of 1996 (Public Law 104-267), 

established procedures designed to identify, conserve, and enhance Essential Fish Habitat (EFH) for those 

species regulated under a federal fisheries management plan. The MSA requires federal agencies to 

consult with NOAA Fisheries on all actions or proposed actions authorized, funded, or undertaken by the 

agency that may adversely affect EFH (MSA §305(b)(2)). 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 NEPA, the Fish 

and Wildlife Coordination Act, or the ESA, to reduce duplication and improve efficiency (50 CFR 

600.920(f)). As part of the consultation process, the FERC has prepared an EFH Assessment, which is 

included in Section 4.5.2 of this EIS. 

Section 106 of the NHPA requires the FERC to take into account the effects of its undertakings 

on properties listed in or eligible for listing in the National Register of Historic Places (NRHP), including 

prehistoric or historic sites, districts, buildings, structures, objects, or properties of traditional religious or 

cultural importance, and to afford the Advisory Council on Historic Preservation (ACHP) an opportunity 

to comment on the undertaking. The FERC has requested that Bayou Casotte Energy, as a non-federal 

party, assist in meeting the FERC’s obligation under Section 106 by preparing the necessary information 

and analyses as required by the ACHP procedures in 36 CFR 800. Section 4.10 of this EIS provides 

additional discussion on the status of the NHPA review for the proposed Project. 

The Coastal Zone Management Act (CZMA) calls for the “effective management, beneficial use, 

protection, and development” of the nation’s coastal zone and promotes active state involvement in 

achieving those goals. As a means to reach those goals, the CZMA requires participating states to 

develop management programs that demonstrate how these states will meet their obligations and 

responsibilities in managing their coastal areas. In the state of Mississippi, the Department of Marine 

Resources is responsible for reviewing federal agency actions and activities to ensure that they are 

consistent with the Mississippi Coastal Management Program (CMP). Because Section 307 of the CZMA 

requires federal agency activities to be consistent to the maximum extent practicable with the enforceable 

policies of a management program, the FERC requires that Bayou Casotte Energy seek a determination of 

consistency with Mississippi’s CMP. Section 4.7.5 of this EIS provides additional discussion of the 

Mississippi CMP and the status of the consistency review for the proposed Project. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Besides the FERC, other federal agencies have responsibilities for issuing permits or approvals to 

comply with various federal laws and regulations. For example, the COE would issue permits under the 

Clean Water Act (CWA) and the Rivers and Harbors Act; the EPA has regulatory authority under the 

CWA and the Clean Air Act (CAA); and the Coast Guard has responsibilities relating to LNG waterfront 

facilities under 33 CFR 127. Several Mississippi state agencies have delegated responsibilities under the 

CZMA, CWA, and CAA. Major permits, approvals, and consultations required for the proposed Casotte 

Landing Project are identified in Table 1.3-1. 

TABLE 1.3-1 

Major Permits, Approvals, and Consultations for the Casotte Landing Project 

Agency Permit/Approval/Consultations a Agency Action 

FEDERAL 

Federal Energy Regulatory 

Commission 

Authorizations to construct and 

operate an LNG import facility 

under Section 3 of the National Gas 

Act 

Determine whether the 

construction and operation of 

the LNG terminal and natural 

gas pipeline are in the public 

interest. 

 National Environmental Policy Act 

(NEPA) 

Preparation of an 

Environmental Impact 

Statement. 

Advisory Council on Historic 

Preservation 

Comment on the project and its 

effect on historic properties under 

Section 106 of the National Historic 

Preservation Act (NHPA) 

Comment on the undertaking 

and its effects on historic 

properties. 

Authorization for activities that will 

occupy, fill, or grade land in a 

floodplain, streambed, or channel of 

a stream or other waters of the U.S. 

under Section 10 of the Rivers and 

Harbors Act of 1899 

Consider issuance of permit for 

placement of structures or work 

in, or affecting, navigable 

waters of the United States. 

U.S. Army Corps of Engineers (COE) 

Authorization to discharge dredged 

or fill material into waters of the 

United States under Section 404 of 

the Clean Water Act (CWA) and 

Section 103 of the Marine 

Protection, Research, and 

Sanctuaries Act (MPRSA) 

Consider issuance of permit for 

the placement of dredge or fill 

material into all waters of the 

United States, including 

wetlands. 

 Ocean Dredged Material Disposal 

Site (ODMDS) Management 

Approval and coordination for 

disposal of dredge material 

U.S. Department of Commerce 

 National Oceanic and 

 Atmospheric Administration, 

 National Marine Fisheries 

 Service 

Consultation regarding compliance 

with Section 7 of the Endangered 

Species Act; the MagnusonStevens Fishery Conservation and 

Management Act; and the Marine 

Mammal Protection Act 

Consult on marine and 

anadromous endangered and 

threatened species essential 

fish habitat, and protected 

marine mammals. 

U.S. Department of the Interior 

 U. S. Fish and Wildlife Service 

Consultation regarding compliance 

with Section 7 of the Endangered 

Species Act, the Migratory Bird 

Treaty Act, the Marine Mammal 

Protection Act, and the Fish and 

Wildlife Coordination Act 

Consult on endangered and 

threatened species, migratory 

birds, and marine mammals. 

General consultation regarding 

conservation of fish and wildlife 

resources. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 1.3-1 (continued) 

Major Permits, Approvals, and Consultations for the Casotte Landing Project 

Agency Permit/Approval/Consultations a Agency Action 

FEDERAL(continued) 

Section 404 of the CWA (veto 

power for wetland permits issued 

by the COE) 

Oversee issuance of the 

Section 404 permit. 

Section 402, CWA, National 

Pollutant Discharge Elimination 

System (NPDES) Permit 

Review and issue permit for 

activities associated with 

pipeline and aboveground 

facilities construction. 

U.S. Environmental Protection 

Agency 

 – Region 4 

Clean Air Act permits for the 

construction of a stationary source 

of air pollutant emissions and for 

operation of the source 

Permitting authority delegated 

to the Mississippi Department of 

Environmental Quality. 

 ODMDS Permit Approval and coordination for 

disposal of dredge material. 

U.S. Department of Homeland 

Security 

 U.S. Coast Guard 

33 CFR 127, Letter of 

Recommendation 

The Captain of the Port 

determines the suitability of the 

waterway for issuance of a 

Letter of Recommendation to 

the operator. 

 Waterfront Facilities Handling 

Liquefied Natural Gas and 

Liquefied Hazardous Gas; 

Permission to establish Aids to 

Navigation 

Review waterfront facilities 

handling LNG 

 Navigation and Shipping 

Consultation, administer approval 

for Maritime Transportation Act, 

and OPA-90 Spill Response Plan 

Consult on navigation and 

shipping, Facility Operations 

Manual, Emergency Response 

Manual, and Safety and 

Security Plan. 

U.S. Department of Transportation 

 Research and Special 

 Programs Administration 

LNG Facilities Petition for Approval 

Consultation as required by section 

311 of the Energy Policy Act of 

2005 and section 3 of the NGA 

Consider issuance of approval 

that the new LNG facility meets 

standards governing siting, 

design, installation, personnel 

qualifications, and training. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 1.3-1 (continued) 

Major Permits, Approvals, and Consultations 

for the Casotte Landing Project 

Agency Permit/Approval/Consultations a Agency Action 

STATE 

Mississippi Department of 

Environmental Quality 

Facility Air Permit 

NPDES Construction Stormwater 

Permit 

NPDES Industrial Stormwater 

Permit 

NPDES Hydrostatic Discharge 

Permit 

Section 401 Water Quality 

Certification 

Water Withdrawal and Discharge 

Permit 

Concrete Batch Plant Air and Water 

Permits 

Stormwater Pollution Prevention 

Plan (SWPPP) 

Spill Prevention, Control and 

Countermeasure Plan (SPCC) 

Air Permits

Consult on and approval of air 

permits 

PSD applicability determination 

review 

Issuance of New Source 

Review (NSR) / Title V air 

Water Permits

Issuance of Construction 

Stormwater, Industrial 

(Operation) Stormwater, and 

Hydrotest Permits. 

Issuance of Concrete Bath Plant 

Water Permit 

Issuance of Section 401 

Certification 

Approval of SPCC and SWPPP 

Plans 

Mississippi Department of Marine 

Resources 

Coastal Wetland Permit 

Coastal Zone Consistency 

Determination 

Consult on, and issuance of, 

Coastal Wetland Permit. 

Consult on Coastal Zone 

Consistency Determination. 

Mississippi Department Archives and 

History – State Historic Preservation 

Officer 

National Historic Preservation Act, 

Section 106 Review 

Consult on, and approval of, 

Cultural Resources Review. 

Mississippi Museum of Natural 

Science (Department of Wildlife 

Fisheries and Parks) – Natural 

Heritage Program 

Consultation regarding threatened 

and endangered species 

Consult on state threatened and 

endangered species that may 

be affected by the Project. 

Mississippi State Fire Marshal Fire Codes and Standards Consult on state and local fire 

and law enforcement services. 

Mississippi Department of 

Transportation 

Traffic Planning Consult on traffic plans, material 

delivery/shipments, and access. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 1.3-1 (continued) 

Major Permits, Approvals, and Consultations 

for the Casotte Landing Project 

Agency Permit/Approval/Consultations a Agency Action 

LOCAL 

Jackson County Port Authority – Port 

of Pascagoula 

Navigation and Shipping 

Consultation 

Consult on navigation and 

shipping, and the Maritime 

Transportation Securities Act. 

Local, County, and City Police, Fire, 

Enforcement and Community 

Agencies/Commissions 

Consultation on Emergency 

Response Plans, utilities, zoning 

and ordinances, and Building and 

Construction Permits 

Consult, and continue review 

through construction planning 

phase, on water connection fee, 

local building permits, 

occupancy permit for new 

structures, state road tie-in 

permit, public utility tie-in permit 

(water and power), state/local 

access permits for truck traffic, 

electrical connection permit, 

excavation permit, notice to 

mariners, navigation aids, 

coordination with pilots and 

marinas. 

____________ 

NOTES: 

a A number of the permits described provide agencies, the public, and other stakeholders the opportunity to review and 

comment on the Project (e.g., the FERC’s NEPA process, COE’s Section 10/404 permit, etc.). 

The EPA has the authority to review and veto COE decisions on Section 404 and 

Section 103 permits. The EPA also has regulatory authority under Section 402 of the CWA as well as the 

CAA. In Mississippi, the EPA provides review and oversight of these regulations but has delegated 

permitting authority to the MDEQ. 

The FERC encourages cooperation between applicants and state and local authorities, but this 

does not mean that state and local agencies, through applications of state and local laws, may prohibit or 

unreasonably delay the construction or operation of facilities approved by the FERC. Any state or local 

permits issued with respect to jurisdictional facilities must be consistent with the conditions of any 

authorization issued by the FERC.3

 

3

 See, e.g., Schneidewind v. ANR Pipeline Co., 485 U.S. 293 (1988); National Fuel Gas Supply v. Public Service 

Commission. 894 F.2d 571 (2d Cir. 1990); and Iroquois Gas Transmission System, L.P., et al., 52 FERC ¶ 61,091 

(1990) and 59 FERC ¶ 61,094 (1992). 

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1.4 PUBLIC REVIEW AND COMMENT 

On February 10, 2005, Bayou Casotte Energy filed a request with the FERC to implement the 

Commission’s Pre-filing Process for the Casotte Landing Project. At that time, Bayou Casotte Energy 

was in the preliminary design stage of the proposed Project and no formal application had been filed with 

the FERC. On March 2, 2005, the FERC granted Bayou Casotte Energy’s request and established a 

pre-filing docket number (PF05-9-000) to place information filed by Bayou Casotte Energy and related 

documents issued by the FERC into the public record. The purpose of the Pre-filing Process is to 

encourage the early involvement of interested stakeholders, facilitate interagency cooperation, and 

identify and resolve issues before an application is filed with the FERC. 

The FERC formally introduced the Pre-filing Process to various Project stakeholders by issuing a 

notice titled Pre-Filing Process Review: Casotte Landing LNG Project (Docket No. PF05-09-000). This 

Pre-filing Notice, issued on March 11, 2005, was sent to interested parties including federal, state, and 

local government agencies; elected officials; environmental and public interest groups; Native American 

tribes; local libraries and newspapers; and landowners within 0.5 mile of the proposed LNG terminal. 

On April 7, 2005, the FERC issued a Notice of Intent to Prepare an Environmental Impact 

Statement for the Proposed Casotte Landing Project, and Request for Comments on Environmental 

Issues, and Notice of Public Scoping Meeting, and Site Visit for Both Casotte Landing LNG Project and 

LNG Clean Energy Project (NOI). The NOI was sent to many of the same interested parties as the first 

notice. Both of these notices encouraged Project stakeholders or interested parties to provide input on 

environmental issues that should addressed during the environmental review process. The NOI 

specifically requested comments before May 6, 2005. In total, five comment letters were received by the 

FERC in response to the Pre-filing Notice and the NOI. 

On April 20, 2005, the FERC staff conducted an inspection of the proposed terminal site that was 

open to the public. Later that evening, the FERC conducted a public scoping meeting in Pascagoula, 

Mississippi to provide an opportunity for the general public to learn more about the Casotte Landing LNG 

Project and the LNG Clean Energy Project and to participate in the analysis by commenting on issues to 

be included in the EIS. Nine people commented at the meeting, primarily regarding the impacts of the 

proposed Project on the local socioeconomic conditions and safety. A transcript of these comments is 

part of the public record for the Casotte Landing Project. 

Table 1.4-1 lists the issues identified during the public scoping process for the Casotte Landing 

Project. Most of the comments received on the project related to LNG safety, alternatives, ship traffic, 

commercial/recreational boating and fishing, Gulf sturgeon critical habitat, wetlands, and dredged 

material placement. 

On October 31, 2005, the FERC issued a Notice of Application (Docket No. CP05-420-000), 

which announced the filing of an application by Bayou Casotte Energy and a final opportunity to submit 

comments. The FERC’s comment period closed on January 30, 2006. In total, 2 additional comment 

letters were received by the FERC in response to Notice of Application. 

The Coast Guard published a notice in the Federal Register on November 17, 2005 stating that it 

was preparing a LOR as to the suitability of the Pascagoula Bar, Horn Island Pass, Lower Pascagoula, and 

Bayou Casotte Channels (collectively identified as the waterway) for LNG marine traffic. On December 

7, 2005, the Coast Guard conducted a public meeting in Pascagoula to provide an opportunity for the 

general public to provide comments on waterway suitability and maritime safety and security aspects of 

the proposed LNG facilities. Four people commented at the meeting and four comments were received in 

writing following the meeting. The majority of the comments concerned safety and security of the port, 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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safety and security of the LNG marine traffic, and impacts to recreational boaters and commercial fishing 

vessels. A transcript of these comments and the Coast Guard Response to them is part of the public 

record for the Casotte Landing Project. 

TABLE 1.4-1 

Primary Issues Identified and Comments Received During the Public Scoping Process 

for the Casotte Landing LNG Project 

Issue/Specific Comment 

EIS Section 

Addressing 

Comment 

GENERAL 

Purpose and need of proposed Project; natural gas markets; local and national benefits. 1.1 

Other permit requirements. 1.3 

More inclusive environmental mailing list; broader distribution of Project notices. 1.4 

PROJECT DESCRIPTION 

Need for additional pipeline expansion; existing pipeline capacities. 2.1 

Description of LNG carrier unloading procedures. 2.1.1 

Description of vaporization system(s). 2.1.1.3 

Description of dredging operations; maintenance dredging plans. 2.4.1.1, 2.7.1 

Operation and maintenance requirements; employee training/licensing standards. 2.7 

ALTERNATIVES 

Alternative vaporization technologies; negative impacts of open loop/seawater vaporization. 3.5.2 

Alternatives to LNG as a source of energy; energy conservation. 3.2.2 

System alternatives; expansion of existing LNG terminals or industrial facilities. 3.3 

LNG terminal at alternative site offshore. 3.3.2 

Consideration of alternative LNG terminal sites; site LNG terminal closer to market area. 3.4.1 

Alternative dredged material placement sites. 3.7 

SOILS AND SEDIMENTS 

Need for sediment sampling prior to dredging and dredged material placement. 4.2.2 

Mitigation during dredging to reduce turbidity and potential spread of contaminants. 4.3.2.2 

Describe dredged material placement locations; upland placement of dredged materials. 4.2.2 

WATER RESOURCES 

Water quality issues at dredged material placement location(s). 4.3.2.2 

VEGETATION 

Introduction of invasive species. 4.4.2 

WETLANDS 

Wetland impacts at LNG terminal and along pipeline route; wetland mitigation. 4.4.3, 4.4.4 

WILDLIFE AND AQUATIC RESOURCES 

Impacts on marine mammals, fisheries, and aquatic habitats, including essential fish habitat; 

habitat impacts should be mitigated. 

4.5 

Potential impacts of ballasting operations on aquatic organisms. 4.5.2.2 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 1.4-1 (continued) 

Primary Issues Identified and Comments Received During the Public Scoping Process for the 

Casotte Landing LNG Project 

Issue/Specific Comment 

EIS Section 

Addressing 

Comment 

WILDLIFE AND AQUATIC RESOURCES (continued) 

Need for pre- and post-construction benthic surveys. 4.5.2.2 

THREATENED AND ENDANGERED SPECIES 

Potential impacts on threatened and endangered species (e.g., Gulf sturgeon, sea turtles); 

impacts on designated critical habitat.

4.6 

Endangered Species Act consultation requirements. 4.6 

LAND USE, RECREATION, AND VISUAL RESOURCES 

Impacts on other local land uses and recreation (e.g., other industries, recreational boating, 

fishing, shrimping). 

4.7.1, 4.7.3 

Impacts on existing special management areas and mitigation sites. 4.7.3 

Visual impact of LNG terminal and LNG marine traffic on Gulf Islands National Seashore and 

the areas’ natural scenic qualities. 

4.7.4 

SOCIOECONOMICS 

Project impacts on property values and insurance rates. 4.8.4 

Insurance/liability issues. 4.8.4 

Negative economic impacts associated with LNG facility development; discouraging other 

economic development. 

4.8 

TRANSPORTATION AND TRAFFIC 

Marine transportation; volume of LNG ship traffic; ship/boat traffic impacts. 4.9.1 

AIR QUALITY 

Emission of pollutants and potential venting and/or flaring of natural gas. 4.11.1 

Project emission impacts on local attainment levels. 4.11.1 

RELIABILITY AND SAFETY 

LNG terminal and ships as target for terrorists. 4.12.6 

Reliability of facility and ship operations. 4.12 

Risks associated with hurricanes. 4.12, 4.1.3.5 

Risks of ship collisions, allisions, and groundings. 4.12.5 

Risks to nearby refinery. 4.12.4 

Risks associated with operation of nearby facilities (e.g., flares associated with refinery; 

accidents at nearby facilities). 

4.12.4 

Contamination of LNG; explosive properties of LNG. 4.12.1 

History of LNG accidents. 4.12 

Safety, security, maintenance procedures at the LNG terminal and on the ships; facility 

lighting, guards, cameras, and patrols. 

4.12 

U.S. Department of Transportation regulations; inspection requirements. 4.12 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 1.4-1 (continued) 

Primary Issues Identified and Comments Received During the Public Scoping Process for the 

Casotte Landing LNG Project 

Issue/Specific Comment 

EIS Section 

Addressing 

Comment 

RELIABILITY AND SAFETY (continued) 

Emergency response procedures and equipment. 4.12.5 

Costs of providing federal, state, and local emergency response and security services. 4.12.5 

CUMULATIVE IMPACTS 

Cumulative impacts of two LNG terminals in the Pascagoula area. 4.13 

Broader/regional examination of cumulative impacts; cumulative impacts and risks of LNG 

facilities. 

4.13 

Cumulative impact analysis following guidelines developed by the U.S. Army Corps of 

Engineers. 

4.13 

Air quality issues, particularly given other industrial activities in the area. 4.13.9 

On April 5, 2006, the FERC staff conducted a cryogenic design and technical conference with 

Bayou Casotte Energy personnel in Mobile, Alabama to discuss design and engineering aspects of the 

Casotte Landing LNG Project. The meeting was limited to existing parties to the proceeding (i.e., anyone 

who specifically requested to intervene as a party). Attendees included agency representatives (U.S. 

Department of Transportation Pipeline and Hazardous Materials Safety Administration and Coast Guard), 

industry representatives, and other interested parties. 

In addition to the public notice and scoping process discussed above, the FERC conducted agency 

consultations and participated in interagency meetings to identify issues that should be addressed in this 

EIS. These activities included participation in interagency meetings in Pascagoula, Mississippi, on April 

20, and August 4, 2005, to discuss the proposed Project and its associated environmental review process 

with other key federal and state agencies. These agencies included the COE; Coast Guard; NOAA 

Fisheries; FWS; DOT; MDEQ; MDMR; and the Gulf States Marine Fisheries Commission. 

We have consulted with the U.S. Department of Defense (DOD) as required by the Energy Policy 

Act of 2005 (EPAct) and section 3 of the NGA to determine if there are any impacts associated with the 

project on training or activities on any military installations. No comments or concerns were received 

from any branch of the military or a military installation in reply to the FERC's scoping notice issued in 

March 2005. 

In addition, in letters dated January 30, 2006 to branches of the military and the DOD, we 

requested any information on impacts to military installations. Because no impacts have been identified, 

we conclude that there is no impact to military installations associated with this project, and therefore, no 

concurrence from the Secretary of Defense is required under the EPAct. 

This final EIS was mailed to the agencies, individuals, and organizations on the mailing list 

provided in Appendix A and submitted to the EPA for formal issuance of a NOA. In accordance with 

CEQ’s regulations implementing NEPA, no agency decision on a proposed action may be made until 

30 days after the EPA publishes a NOA of the final EIS. However, the CEQ regulations provide an 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
1-15

exception to this rule when an agency decision is subject to a formal internal process that allows other 

agencies or the public to make their views known. In such cases, the agency decision may be made at the 

same time the notice of the final EIS is published, allowing both periods to run concurrently. Should the 

FERC issue authorization for the Casotte Landing LNG Project for the proposed action, it would be 

subject to a 30-day rehearing period. Therefore, the FERC could issue its decision concurrently with the 

EPA’s NOA. 

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2-1

2.0 DESCRIPTION OF THE PROPOSED ACTION 

The FERC is the federal agency responsible for authorizing applications to construct and operate 

onshore LNG import and interstate natural gas transmission facilities. The Coast Guard is the federal 

agency responsible for determining the suitability of the waterway for LNG marine traffic. The Coast 

Guard is also the federal agency responsible issuing a LOR regarding the suitability of the waterway for 

LNG marine traffic. 

The proposed action before the FERC is to consider issuing to Bayou Casotte Energy a Section 3 

authorization for the LNG import facilities. The proposed action before the Coast Guard, as required by 

their regulations in 33 CFR 127.009, is to consider issuing Bayou Casotte Energy a LOR finding the 

waterway suitable for LNG marine traffic associated with the proposed Casotte Landing Project with 

conditions. The conditions include: 

1) establishment of a moving safety zone during LNG vessels’ transit of the waterway, 

including requirements for daylight transit and one way LNG marine traffic on the 

waterway, as well as another safety zone around the LNG facility while the LNG vessels 

are moored; 

2) an annual review of the facility’s WSA by the applicant to evaluate if any conditions in 

the waterway have changed that would require issuance of a new LOR, with submittal of 

such annual reviews to the COTP for consideration and issuance of a new LOR, if 

required; 

3) LNG marine traffic must navigate the waterway from the outer sea buoy to the berthing 

with harbor pilots onboard; 

4) that tug assistance be provided as deemed necessary by the Pascagoula pilots; 

5) that all LNG marine traffic make a SECURITE broadcast prior to crossing the Gulf 

Intracoastal Waterway; 

6) implementation of a Coast Guard approved LNG Vessel Transit Management Plan; and 

7) that adequate Coast Guard resources be available to implement the security measures 

described above. 

The Coast Guard, with input from the Area Maritime Security Committee (AMSC), has 

completed an initial review of Casotte Landing’s WSA in accordance with the guidance in Coast Guard 

NVIC 05-05. 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. The WSA itself 

is designated Sensitive Security Information as defined in Title 49 CFR Part 1520. Because any 

unauthorized disclosure of these details would be employed to circumvent the proposed security 

measures, they are not releasable to the public. 

As a result of this review, the Coast Guard preliminarily advised the FERC by letter of April 1, 

2006, and modified in a letter of September 5, 2006, that the Pascagoula Bar, Horn Island Pass, Lower 

Pascagoula and Bayou Casotte Channels can accommodate the LNG marine traffic associated with the 

project, depending on the evaluation of certain conditions listed above (see Appendix G). 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
2-2 

2.1 PROPOSED FACILITIES 

Bayou Casotte Energy proposes to construct and operate a new LNG import, storage, and 

vaporization terminal on the eastern shoreline of Bayou Casotte. The proposed LNG terminal would be 

located adjacent to Chevron’s existing Pascagoula Refinery in Pascagoula, Jackson County, Mississippi. 

In addition, Bayou Casotte Energy proposes to construct up to five connections to existing natural gas 

pipeline transmission systems located in the vicinity of the proposed LNG terminal. The proposed 

Project would allow LNG to be imported from areas with natural gas reserves throughout the world to the 

LNG terminal via ocean-going LNG carriers. At the proposed LNG terminal, LNG would be unloaded, 

stored, and regasified for delivery via pipeline. The proposed pipeline interconnects would allow natural 

gas from the LNG terminal to be sent to markets throughout Mississippi and the southeast United States 

via pipeline interconnects with a number of existing intrastate and interstate pipeline systems. 

Figure 2.1-1 illustrates the general location of the proposed Project. The following section describes the 

proposed LNG terminal, the LNG carriers that would supply the terminal, and the pipeline facilities. 

2.1.1 LNG Terminal 

The proposed LNG terminal would include a double-berth slip capable of accommodating an 

LNG carrier and a crude oil tanker, unloading facilities (marine terminal), three LNG storage tanks, vapor 

handling equipment, six intermediate fluid vaporizers and related LNG regasification systems, and 

various utilities and support facilities. The terminal would be located on property adjacent to the Chevron 

Pascagoula Refinery (Refinery). A layout of the proposed facilities is depicted in Figure 2.1.1-1. 

The proposed LNG terminal would include an unloading slip approximately 900 feet wide by 

1,450 to 2,150 feet long (length varies due to an angled alignment) that would be constructed by dredging 

the western portion of the 259.4-acre site to a depth of 42 feet below mean lower low water (MLLW). 

Construction of the unloading slip off of Bayou Casotte would provide a protected double-berth for the 

offloading of LNG carriers and crude oil vessels (nonjurisdictional). The 60-degree angled design of the 

unloading slip would avoid the need for additional dredging of a turning basin, which would otherwise be 

required at the entrance of the slip to allow for ship maneuvering. 

The proposed terminal slip would consist of one berth designed for port mooring to receive and 

unload LNG carriers ranging from 125,000-m3

 to 200,000-m3 capacity. The nonjurisdictional crude slip 

would be designed for starboard mooring of crude vessels ranging from 96,000 to 155,000 deadweight 

tonnage (DWT). The LNG carrier berth would include a single-level unloading platform consisting of 

reinforced concrete deck and beams supported on piles. The berth would be designed to support the three 

LNG unloading arms and a vapor return arm, plus associated valves and piping, a gangway tower, 

firewater monitors, anemometer, and firewater monitor pumps. In addition, the slip would include a berth 

to accommodate the docking of up to three tugs. 

The design of each berth includes two to three breasting dolphins that would accommodate lateral 

loads from moored vessels in the berth and protect the unloading platform. Each breasting dolphin would 

be constructed of reinforced concrete structures on piles and fitted with a remotely operated quick-release 

triple mooring hook and an energy-absorbing fender. Side slopes within the berth would be constructed 

at a 5:1 slope and covered with rock riprap overlaid on geotextile fabric for scour protection. 

Six mooring dolphins, comprised of reinforced concrete structures on piles, would be installed at 

each berth. The breasting and mooring dolphins would be connected to the unloading platform by steel 

truss walkways. The berth would be supplied with electrical power for equipment and lighting systems, 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Page 2-3 

Figure 2.1-1 Proposed Casotte Landing Project 

General Project Location 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

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FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Page 2-4 

Figure 2.1.1-1 Proposed Casotte Landing Project LNG Terminal 

Site Layout Ship Berth and Unloading Facilities 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
2-5

potable water, communications and instrument cabling, and nitrogen for purging the LNG unloading 

arms. Steel trusses and girders would support piping and cabling. 

Individual trestles extending from the top of the beam to the edge of the unloading platform 

would support electrical cables and piping for the LNG, firewater, and other utilities, and would include a 

12-foot-wide vehicle roadway. The trestle would be a concrete structure supported on piles. Pipe racks, 

utility piping, and electrical cable trays would be supported off the deck, and light poles would be 

installed on the end of the pile caps to provide area and hazard lighting. 

Spill collection troughs would be positioned beneath the LNG unloading line that would drain to 

a spill impoundment sump in the event of LNG spillage. The unloading platform would be curbed to 

confine LNG spillage and its surface sloped to a collection point. Drainage from the collection point 

would flow to the spill impoundment sump by means of the piping collection troughs. Any spilled LNG 

would be covered by high expansion foam and allowed to evaporate. No active recovery of spilled LNG 

would take place. 

LNG would be transferred from LNG carriers to the onshore LNG storage tanks using onboard 

pumps. The berth would include a total of four manifold 16-inch-diameter unloading arms plus one 

16-inch-diameter vapor return arm. This configuration would transfer LNG at a rate of 15,000 m3

/hour. 

The vapor return line would be used to return tank vapors generated during the unloading operation. The 

natural gas vapor would be returned to the carrier tanks to maintain pressure. One of the four unloading 

arms would be a hybrid arm suitable for either liquid or vapor service. This hybrid arm would be 

available for vapor service in the event the dedicated vapor arm is unavailable. 

Following ship berthing and connection of the liquid and vapor loading arms, LNG transfer to the 

LNG storage tanks would occur through two 32-inch-diameter, vacuum-insulated, double-wall pipes. 

During periods when there is no unloading operation (in holding mode), LNG would be continuously 

circulated through the transfer lines to maintain the lines at cryogenic temperature. Maintaining the 

transfer lines at cryogenic temperatures prevents thermal shock to the piping and the generation of 

excessive vapor upon initiation of the next unloading operation. 

2.1.1.1 LNG Storage Tanks 

The LNG would be stored in three insulated, full-containment tanks, each sized to store a 

working capacity of 160,000 m3

 of LNG at a design temperature of –270.4 °F and a design operating 

pressure of 4.12 pounds per square inch gauge (psig). Figure 2.1.1-2 depicts the conceptual design of the 

proposed storage tanks. Each tank would consist of a primary inner container of nine percent nickel steel, 

a secondary outer container of pre-stressed concrete, a reinforced concrete domed roof, and an aluminum 

insulated support deck suspended from the outer container roof over the inner container. The storage 

tanks would be designed and constructed so that both the inner primary and the outer secondary 

containers are completely self-supporting and capable of independently containing the stored LNG. The 

outside diameter of the outer tank would be approximately 269 feet and the height to the top of the dome 

would be approximately 166 feet above grade. 

The space between the walls of the inner container and the outer container would be insulated 

with expanded perlite. Similarly, the aluminum support deck suspended from the concrete roof would be 

insulated with cellular glass. The cellular glass insulation under the inner container’s base would be 

capable of supporting the weight of the inner container and the LNG. These insulation materials would 

allow the LNG to be stored at a temperature of -270 °F while maintaining the outer container surface near 

ambient temperature. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Figure 2.1.1-2 

Proposed Casotte Landing Project 

Conceptual Design of the LNG Storage Tanks 

2-6

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2-7

The outer concrete container would be lined on the inside with carbon steel plates. This carbon 

steel liner would serve as a barrier to keep atmospheric moisture from reaching the insulation inside the 

outer container. Under normal operating conditions the inner primary container would contain the 

cryogenic liquid. However, the outer container would also be capable of containing the cryogenic liquid 

as well as the vapors resulting from accidental product release from the inner container. The vapor 

pressure from the LNG would be equalized between the two containers through ports in the suspended 

insulation deck, with all vapors fully contained by the outer container. The internal design pressure of the 

outer container would be 4.12 psig. 

To enhance the safety of the tank, all connections to the tank would be made through the tank 

roof so that a failure of a line would not create a leak in the tank. LNG would be unloaded from the tank 

through connections in the top that would have inlets at various levels within the storage tank. Each tank 

would be equipped with three fully submerged in-tank pumps, each sized to transfer LNG to the 

vaporizers at a rate of 4,211 gallons per minute (gpm). The LNG in-tank pumps would be mounted 

within columns that extend from the bottom of the tanks through the outer tank roof. 

2.1.1.2 Vapor Handling System 

During normal operations, a small amount of LNG within the storage tanks would vaporize 

primarily due to heat inputs from ambient conditions and in-tank pumps, as well as barometric pressure 

changes. In order to avoid natural gas releases to the atmosphere, the vapor handling system would 

collect and transfer gas originating from the storage tanks. This boil-off gas (BOG) would either be 

transferred back to the LNG carriers or sent out through the natural gas pipeline interconnects. 

During LNG carrier unloading operations, a portion of the BOG would be returned to the carrier 

by a ship vapor return (SVR) blower to compensate for the volume of liquid pumped out to maintain the 

carrier’s tank pressure. BOG that is not returned to the carrier would be compressed, condensed by direct 

contact with LNG, and then combined with the sendout natural gas. A total of two identical reciprocating 

BOG compressors would be provided. One of the compressors would serve as a backup. The 

compressors would be sized for the maximum vapor release rate that occurs during carrier unloading. 

The redundant BOG vapor handling system prevents BOG from being released to the atmosphere during 

both unloading and normal holding operations. 

2.1.1.3 Vaporization System

LNG can be returned to a gaseous state through warming. The vaporization system is a critical 

operation with several available technologies. The close proximity between the proposed terminal site 

and the Refinery was chosen to take advantage of synergies between the two facilities (waste heat from 

refinery operations and the need for heat to vaporize the LNG). 

LNG vaporization would be accomplished by heat exchange utilizing a closed-loop circulation 

solution of an intermediate fluid vaporizer (IFV). Each IFV is a vertical shell and tube exchanger with 

LNG on the tube side and a 25 percent by weight propylene glycol (PG) solution on the shell side as the 

intermediate fluid. The PG solution is pumped in a closed loop by glycol circulation pumps (five 

operating plus one installed spare). The circulating PG is heated by direct cross exchange with cooling 

water from the Refinery in 12 plate and frame heat exchangers (10 operating plus two installed spares) 

located at the LNG Terminal. The cold water from these exchangers is returned to the Refinery cooling 

tower(s). Two separate piping systems would be constructed to circulate cooling water from the Refinery 

to the glycol/water exchangers. The main water loop would use six pumps (five operating plus one 

installed spare) to circulate water from the Refinery Cooling Tower 1 (CT1). Each circulation pump 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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would have a capacity of 13,800 gpm. The second water loop would use three pumps to circulate water 

from the Refinery Cooling Tower 2 (CT2). The CT2 loop would be used as a back-up to the CT1 loop. 

As a potential back-up to the heating provided by the refinery cooling water system, two natural 

gas fired process heaters would supplement or replace a portion of the heat normally provided by the heat 

exchange system with up to 560 million British thermal units per hour (MMBTU/hr) (combined). The 

process heaters would warm the intermediate fluid normally utilized in the IFVs during periods when the 

refinery cooling water system is unavailable or inadequate (for example, full or partial refinery outage or 

winter months with colder supply water). The process heaters would support a backup throughput rate of 

0.9 BSCFD. The same PG solution would be used to circulate hot PG to the NGL plant reboilers 

(70 MMBTU/hr). A discussion of vaporization alternatives is included as Section 3.5.2. 

As a safety precaution, the sendout pumps and vaporizers would be installed within curbed spill 

containment areas that would drain to the process area sump. 

2.1.1.4 Utilities and Support Facilities 

The proposed terminal would be independent of the Refinery for all utilities except for potable 

water and the circulation water that would be used as the primary heat source for LNG vaporization. 

Primary electric power would be supplied by Mississippi Power Company (MPC) via their transmission 

voltage system. Other utilities would be provided by Jackson County or the local municipality. The 

following sections provide details about each of the varied utility streams that would be required for the 

proposed terminal operations. 

Electrical System 

The source of power for the proposed terminal would be the transmission voltage system of MPC. 

Two transmission lines are planned for this supply. Depending on the availability of power and right-ofway, the transmission lines would be of single circuit or double circuit design. Overhead transmission 

lines would likely be on single structures for increased reliability. The transmission lines would be of a 

radial design and terminate at a breaker at the proposed terminal for each transmission circuit. 

Nitrogen System 

Bayou Casotte Energy would use nitrogen for purging of all the loading arms after unloading 

LNG carriers and for purging of the flare system. Nitrogen would also be supplied to the various terminal 

utility stations for the purpose of purging both the piping and flare systems. The terminal flare system 

would require about 1,700 standard cubic feet per hour (SCFH) of nitrogen for purging on a continual 

basis. A nitrogen generation plant would be provided for onsite storage capacity to reduce the peak 

requirements. 

Buildings 

The proposed LNG terminal would include the following service buildings: 

• Terminal Control Center, administration, warehouse, shop, and security building – a twostory building with approximately 26,400 square feet to house the control centers for the 

marine facilities and terminal. Administrative personnel, security personnel, the warehouse, 

and the shop would also be housed in this building. The building would be equipped with 

smoke detection and fire alarm systems. An automatic sprinkler protection system would be 

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2-9

located in all areas with the exception of the control room. The control room and associated 

equipment room would be provided with a “clean-agent” type gaseous suppression system; 

• LNG Jetty Control Building – one 420-square-foot building at the marine berth to house the 

jetty control room. The building is anchored to the foundation of the jetty structure and 

contains a control room, an air-lock, and a toilet room; 

• BOG Compressor Enclosure – 7,200 square-foot building which would house the BOG 

compressor, a 10-ton electric bridge crane, a hoist, and a trolley; 

• Firewater Pump Houses – two 600 square-foot buildings located at the terminal and on 

Refinery property that would contain the firewater pumps; 

• Instrument Air/Plant Air Shelter – a 3,025 square-foot building would house the air plants; 

• Nitrogen Membrane Package Shelter – a 1,485 square-foot building would protect the 

nitrogen generation equipment; 

• Essential Services Generator Shelter – an essential generator would be housed in a 

1,485 square-foot building; 

• Terminal Main Gate Guard House – a 150 square-foot building in which the security guard 

would be stationed; and 

• Terminal Foam Houses – five 126 square-foot buildings would contain the fire 

fighting system. 

Service and Potable Water System 

Service water would be provided by the Jackson County water system, which is supplied by 

surface waters and piped at a pressure that is suitable for distribution. County water is treated for pH 

control and run through clarifiers to reduce turbidity at the Kreole Pumping station operated by Jackson 

County. County water is not considered to be potable. Service water would be provided to the utility 

stations and the fire water pond. 

Potable water would be supplied from the Refinery potable water supply at a pressure that is 

suitable for distribution. Two wells (north and south tank field) are used to provide potable water to the 

Refinery. At the boiler plant, this water is chlorinated and treated with a food grade phosphate to coat the 

lines. Potable water would be used in all kitchens, wash areas, rest rooms, and safety and eye wash 

stations. Potable water would not be connected to any process system and would be transported by a 

water line wholly on Chevron-controlled property. 

Domestic and Process Waste Treatment System 

Wastewater would be captured and treated on-site at a wastewater treatment facility to be 

installed in the terminal area. Sanitary lift stations would be located near the Administrative/Control 

Building and the LNG Jetty Control Building. Wastewater discharged from the oil-water separator would 

be pumped to the treatment package via the lift station for further treatment and final discharge. Solid 

wastes (sludge) and recovered oil would be trucked off-site for disposal. A peak rate of 675 gallons per 

day would be anticipated. These waste streams would be treated and released in accordance with the 

NPDES permit as administered by the MDEQ. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
2-10

Stormwater Handling and Pollution Prevention 

Stormwater would be collected in surface ditches alongside the roads and hurricane levee, and 

routed to catch basins located throughout the terminal site. Storm water collected inside of the hurricane 

levee would be pumped over the levee to the storm sewer systems outside of the levee. Underground 

sewer pipes would be used to connect catch basins outside of the levee. Stormwater would ultimately be 

discharged to Bayou Casotte via two new outfalls located on the north and south side of the process area. 

Diesel Fuel System 

Diesel would be required for the firewater pumps and the emergency generator. The diesel fuel 

would be delivered by trucks and stored in day tanks. Three 600-gallon tanks would be required for the 

firewater pumps and one 7,450-gallon tank would be required for the emergency generator. The day 

tanks for each firewater pump would be sized for a 24-hour fuel supply. 

Natural Gas Sendout Meter Stations 

As described further in Section 2.1.3, the LNG terminal would also include facilities associated 

with the natural gas pipeline interconnects (for example, meter and regulating equipment and block 

valves). 

2.1.2 LNG Carriers 

LNG would be shipped to the Casotte Landing Project from a variety of sources around the 

world, possibly including Angola, Nigeria, and Venezuela. At this time, Bayou Casotte Energy has not 

confirmed the source(s) of LNG supplies nor the LNG vessels that would be used. Vessels from these 

ports most likely would transit the Caribbean and Yucatan Channel to access the Gulf of Mexico. 

The LNG marine traffic would travel from the Gulf of Mexico to the Horn Island (HI) Buoy prior 

to entering the 5.1-nautical mile (NM)-long, Pascagoula Bar Channel. From the Pascagoula Bar Channel 

the LNG marine traffic would transit into the Horn Island Pass Channel, which is 1.1 NM long. The Horn 

Island Pass Channel terminates into lower Pascagoula Channel, which is 3.8 NM. From the lower 

Pascagoula Channel, LNG marine traffic would proceed into Bayou Casotte Channel. The distance to the 

proposed terminal along this channel is 2.6 NM from the entry point of the Bayou Casotte Channel. The 

Pascagoula Bar Pilots (Pilots) are responsible for scheduling carrier movements, monitoring weather 

conditions, establishing working conditions, and declaring channel closures based on inclement weather. 

Figure 2.1.2-1 illustrates the route that LNG marine traffic would traverse to access the proposed LNG 

terminal. The carriers that transport LNG are specially designed and constructed to transport LNG for 

long distances. LNG carrier construction is highly regulated and consists of a combination of 

conventional ship design and equipment, with specialized materials and systems designed to safely 

contain liquids stored at temperatures of -260°F. 

The following section presents a brief overview of the main design and safety features of a typical 

LNG carrier that might transport LNG to the proposed terminal. 

Profile 

LNG carriers have a distinctive appearance compared with other transport ships. An LNG carrier 

has a high freeboard (the portion of the ship above water) when compared with vessels such as an oil 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Page 2-11 

Figure 2.1.2-1 Proposed Casotte Landing Project Navigation 

Routes to the Port of Pascagoula 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
2-12

tanker, because of the comparatively low density of the cargo. Because of the high freeboard, wind 

velocity can adversely affect the maneuverability of the carrier, particularly at slow speeds, such as during 

docking. 

All LNG carriers are constructed with double hulls while most other liquid transport ships 

presently in use have single-hull construction. Double-hull construction increases the structural integrity 

of the hull system and provides protection for the cargo tanks in case of an accident. The space between 

the inner and outer hulls is used for water ballast. The International Code for the Construction and 

Equipment of Ships Carrying Liquefied Gases in Bulk (Gas Tanker Code) and Coast Guard regulations 

require that LNG carriers meet a Type IIG standard of subdivision, damage stability, and cargo tank 

location. 

The Type IIG design ensures the LNG carrier would withstand flooding of any two adjacent 

compartments without any adverse effect upon the stability of the carrier. Type IIG design also requires 

that the cargo tanks must be a minimum of 30 inches from the outer hull and a minimum distance above 

the bottom of the carrier equal to the beam of the carrier divided by 15, or 6.5 feet, whichever is less. 

This distance is intended to prevent damage to the cargo tanks in case of low energy-type accidents that 

might occur in harbors and during docking. Most large LNG carriers have a distance of 10 to 15 feet 

between the outer hull and cargo tank. 

Hull System 

Containment Systems 

An LNG containment system on LNG carriers consists principally of the cargo tank (sometimes 

called a primary barrier), the secondary barrier, and insulation. The containment system also includes 

cargo monitoring and control and safety systems. 

Three basic tank designs have been developed for LNG cargo containment: prismatic freestanding, spherical, and membrane. The earliest form of LNG containment is the prismatic free-standing 

tank. It consists of an aluminum alloy or nine percent nickel steel, self-supporting tank that is supported 

and restrained by the hull structure. Insulation consists of reinforced polyurethane foam on the bottom 

and the sides, with fiberglass on the top. The spherical tank design, also known as the Moss design, uses 

an unstiffened, spherical, aluminum alloy tank that is supported at its equator by a vertical cylindrical 

skirt, with the bottom of the skirt integrally welded to the carrier’s structure. This free-standing tank is 

insulated with multi-layer close-cell polyurethane panels. In the membrane containment system, the 

carrier’s hull constitutes the outer tank wall, with an inner tank membrane separated by insulation. Two 

forms of membrane are commonly used: the Technigaz membrane using stainless steel and the GasTransport membrane using Invar. 

LNG tankers are of the double-hulled design regardless of the containment system used. Double 

bottom and double sides are provided for the full length of the cargo area and arranged as ballast tanks, 

independent of the cargo tanks. The double-hulled design provides greatly increased reliability of cargo 

containment in the event of grounding and collisions. Further, the segregated ballast tanks prevent ballast 

water from mixing with any residue in the cargo tanks. 

Pressure/Temperature Control 

A basic goal of all LNG containment systems is to maintain the LNG cargo at or above 

atmospheric pressure at the boiling temperature of the LNG (about -260 °F). This is accomplished using 

“auto-refrigeration,” that results from the constant heat flow into the tank and the removal of the 

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associated boil off vapor. The boil off vapor ranges from 0.25 to 0.15 percent (by volume) per day and is 

used to supplement the bunker fuel in the carrier’s boilers. As a result, many existing LNG carriers have 

reduced emissions when compared with conventional oil-fired carriers. However, many of the newer 

LNG carriers that are currently proposed or under construction would have re-liquefaction capabilities, 

and thus, none of the LNG cargo would be consumed by the carrier’s propulsion system. LNG cargo 

tanks are kept under a gas atmosphere at all times so that oxygen is never allowed into the system. 

Ballast Tanks 

Sufficient ballast water capacity must be provided to permit the carrier to return to the loading 

port safely under various sea conditions. LNG cargo tanks are not used as ballast tanks because these 

tanks must contain a minimal amount of LNG to remain at cryogenic temperatures. Consequently, LNG 

carriers must be designed to provide adequate ballast capacity in other locations. 

Ballast water tanks of the LNG carriers are arranged within the LNG carrier’s double hull. It is 

essential that ballast water not leak into the LNG containment system. To reduce the potential for 

leakage, the ballast tanks, cofferdams, and void spaces are typically coated to reduce corrosion. LNG 

carriers are also periodically inspected to examine the coating and to renew it as necessary. 

A ballast control system, which permits simultaneous ballasting during cargo transfer operations, 

is also incorporated into each LNG carrier. This allows the LNG carrier to maintain a near constant draft 

during all phases of its operation to enhance performance. Under normal operating conditions, ballast 

water would be taken onto the carrier during LNG off-loading at the marine terminal. A typical LNG 

carrier would take on about 11 to 14 million gallons of ballast water during the offloading operations. 

Ballast water would not be discharged into the Bayou Casotte area during unloading operations. Further, 

the Coast Guard has developed responses to exotic/invasive organisms associated with ballast water from 

foreign vessels. The Coast Guard Office of Operating and Environmental Standards has 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, remove fouling organisms from hull, piping, and tanks 

on a regular basis, and dispose of any removed substances in accordance with local, state, and federal 

regulations (see Section 4.5.1.4). 

Carrier Safety Systems 

Any LNG carriers used in association with the proposed Project would have to comply with all 

federal and international standards regarding LNG shipping. As such, ships that transport LNG to the 

terminal would be fitted with cargo monitoring and control systems. These systems would automatically 

monitor key cargo parameters while the ship is at sea and during the remote-control phase of cargo 

operations at the unloading terminal. 

The system includes provisions for pressure monitoring and control, temperature monitoring of 

the cargo tanks and surrounding ballast tanks, emergency shutdown of cargo pumps and closing of critical 

valves, monitoring of tank cargo levels, and gas and fire detection. 

The LNG carriers that transport LNG to the terminal would be fitted with many navigation and 

communication systems, including: 

• automatic radar plotting aids (ARPA); 

• digital global positioning system (DGPS); 

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• Automatic identification of ships (AIS); 

• echo depth finders; and 

• satellite communications. 

All LNG carriers also have redundant, independent steering control systems that are operable 

from the bridge or steering gear room to maintain rudder movement in case of a steering system failure. 

Fire Protection 

All LNG carriers arriving at the proposed terminal would be constructed according to structural 

fire protection standards contained in the International Convention for the Safety of Life at Sea (SOLAS). 

This would be done under the review and approval of the Coast Guard. 

LNG carriers using the terminal would also be fitted with active fire protection systems that meet 

or exceed design parameters in Coast Guard regulations and international standards, such as the Gas 

Tanker Code and SOLAS, including: 

• a water spray (deluge) system that covers the accommodation house and Cargo Control 

Room, and all main cargo control valves; 

• a traditional firewater system that provides water to fire monitors on deck and to fire stations 

found throughout the carrier; 

• a dry powder extinguishing system for LNG fires; and 

• a carbon dioxide system for protecting the machinery, ballast pump room, emergency 

generators, and cargo compressors. 

Crew Qualifications and Training 

All officers and crews of the LNG carriers using the terminal would comply with the 

International Convention Standards of Training, Certification and Watch Keeping for Seafarers. Key 

members of the crew must have specific training in the handling of LNG and the use of the safety 

equipment. Officers must receive simulator training in the handling of the carrier and the cargo systems 

specific to the conditions at the Project site. In addition, a local pilot would board each carrier and guide 

it through Bayou Casotte. 

Carrier Selection 

The specific identity of LNG carriers that would unload at the terminal would depend on the 

commercial terms of the LNG purchase agreement(s). Although the Bayou Casotte channel is currently 

only sufficient for LNG carriers with a maximum capacity of approximately 160,000 m3

, the proposed 

Project has been designed to accommodate LNG carriers with capacities ranging from 125,000 to 

200,000 m3 (should the channel be expanded in the future). Assuming that the typical LNG carriers 

visiting the terminal would have a capacity of 145,000 m3

, approximately 170 shipments would be 

expected each year. Typical vessels of this size would be approximately 950 feet in length, and have a 

beam (width) of 145 feet and a draft of 38 feet. Vessels using the terminal would comply with the Coast 

Guard regulations for LNG carriers. This compliance would be demonstrated by the operator of the LNG 

carrier having proper certificates authorizing the transport of LNG as follows: 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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• U.S. Flag LNG Carrier – The Coast Guard Certificate of Inspection must be valid and 

endorsed for the carrier to transport LNG (46 CFR 154, 1979); and 

• Foreign Flag LNG Carrier – The carrier must have a valid Certificate of Compliance issued 

by the Coast Guard. The certificate is issued after the carrier has proved that it complies with 

the Coast Guard regulations and after it has been satisfactorily inspected by a Coast Guard 

Marine Safety Office (46 CFR 154, 1979). 

Both U.S. and foreign flag carriers must be inspected annually by the Coast Guard and the flag 

state. A Coast Guard Certificate of Inspection is required every two years. It is anticipated that Coast 

Guard officers from Sector Mobile, Alabama may board inbound LNG carriers prior to entry into Bayou 

Casotte Harbor for inspection, verification of documentation, and a safety check. Bayou Casotte Energy 

would continually monitor carrier operations to ensure that the operations are according to their 

established procedures and to ensure that the carriers are maintained to all standards. Based on 

discussions with the Pilots, Bayou Casotte Energy anticipates that movement of LNG carriers in the 

shipping channel would be limited to daylight hours. 

2.1.3 Pipeline Interconnects and Associated Aboveground Facilities 

The Casotte Landing Project would include construction and operation of five short, underground 

natural gas pipeline interconnects with associated aboveground facilities. 

Five natural gas pipelines are available for connection at two meter stations on the Refinery 

property. These include the Chandeleur (12-inch-diameter and 16-inch-diameter), Destin (16-inchdiameter), Gulf South (12-inch-diameter), and Gulfstream (36-inch-diameter) pipeline systems. The close 

proximity of interstate natural gas pipelines minimizes the need to establish new pipeline rights-of-way. 

The pipeline interconnect system would consist of a 36-inch-diameter spur line traversing north along 

Ranson Road, then east to the 36-inch-diameter Gulfstream pipeline, where it would tie in via a meter 

station at pipeline milepost (MP) 1.5. This spur would pass adjacent to the 12-inch-diameter Gulf South 

pipeline, the 36-inch-diameter Destin pipeline, the 16-inch-diameter Chandeleur pipeline, and the 

12-inch-diameter Chandeleur pipeline where the lateral pipeline interconnects would be made at a meter 

station located just east of the proposed LNG terminal at MP 0.5 (see Figure 2.1.3-1). 

For each of the proposed pipeline interconnects, a custody transfer meter, owned and maintained 

by the respective pipeline owner, would be located at the tie-in points. Since the length of each 

interconnect is relatively short, block valves would be located at the line origin and termination points. 

Table 2.1.3-1 lists the aboveground facilities associated with the proposed pipeline interconnects. 

Meter runs, consisting of a custody-transfer flow meter, pressure regulator, isolation block valves, 

and all associated instrumentation and controls, would be installed at each interconnect to measure the 

flow of natural gas from the Casotte Landing Project pipeline system to the existing pipelines. Metering 

equipment would be located within a fenced and gated site at the terminus of each interconnect. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Page 2-16 

Figure 2.1.3-1 Proposed Casotte Landing Project 

Pipeline Interconnect System 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
2-17

TABLE 2.1.3-1 

Aboveground Facilities Associated with the Proposed Casotte Landing Project 

Facility Milepost Associated and/or Collocated Facility a

INTERCONNECTS 

Chandeleur Interconnect (12-inch) MP 0.5 Meter station / Interconnect piping 

Chandeleur Interconnect (16-inch) MP 0.5 Meter station / Interconnect piping 

Destin Interconnect MP 0.5 Meter station / Interconnect piping 

Gulf South Interconnect MP 0.5 Meter station / Interconnect piping 

Gulfstream Interconnect MP 1.5 Meter station / Interconnect piping 

NONJURISDICTIONAL FACILITIES 

NGL Pipeline MP 4.3 Meter station / Interconnect piping 

Circulation Water System 

 Cooling Tower 1 MP 0.0 to MP 0.5 System piping 

 Cooling Tower 2 MP 0.4 to MP 0.5 System piping 

_____________ 

a

 Lateral pipelines and interconnect piping are discussed in Section 2.4. 

2.2 NONJURISDICTIONAL FACILITIES 

In addition to the proposed facilities discussed in Section 2.1, the Casotte Landing Project would 

involve a number of other integrally related facilities. These facilities include pipelines, electric 

transmission lines, an electric substation, and a water circulation system that are not regulated by the 

FERC. The relocation of two crude berths would also be required to maintain shipping capacity to the 

Refinery and to take advantage of the dual berth design of the proposed marine terminal. 

Refinery Berth 7, currently located adjacent to the proposed marine terminal, receives shipments 

of crude oil and exports refined products. Refinery Berth 7 would occupy the northern berth of the 

proposed slip. Refinery Berth 6 would be located south within the existing channel. The relocation of 

Refinery Berth 6 alleviates congestion at the petroleum-coke dock. Impacts from the relocation of these 

two refinery berths are included with the impacts from the proposed Project. 

In order to provide power to the proposed terminal, a nonjurisdictional main electrical substation 

and four smaller substations would be constructed on site. The main electrical substation would be 

connected to the existing electric transmission grid by approximately two circuit miles of new rights-ofway. The timing and final routing and design information from MPC is not available at this time; 

however, the probable routing of the lines would follow Highway 611 from a point southwest of MPC’s 

Chevron Cogen 115-kV substation south approximately one-half mile, then west approximately one-half 

mile to a new 560-foot by 300-foot 115-kV substation at the proposed terminal site. 

The primary heat for the proposed Project’s glycol-water intermediate fluid would be provided by 

waste heat that is currently removed by the Refinery’s cooling towers. This approach would generate 

multiple benefits, including fuel and water conservation and reduction of air emissions. Warm water 

from the inlet of Cooling Towers 1 (primary supply) and 2 (secondary supply) would be pumped to the 

proposed terminal, cooled by thermal exchange with the glycol-water intermediate fluid, and then 

pumped back to the Refinery’s cooling water towers through a closed-loop piping system. Waste heat 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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would be supplied to the proposed terminal via a 48-inch pipe from Cooling Tower 1, and via a 42-inch 

pipe from Cooling Tower 2. Under normal operations, Cooling Tower 1 would provide all of the heat 

needed for the proposed LNG facility. However, an additional tie in will be made at Cooling Tower 2 to 

supply a portion of the heat necessary for vaporization of LNG in the event water from Cooling Tower 1 

is unavailable or inadequate to provide the required heating (such as during cold weather). Four parallel 

pipe runs (the two supply lines plus their similar-sized return lines) would be aboveground on concrete 

sleepers within the proposed terminal site and underground where they cross East Hardee Road and 

within the Refinery. The water pipes would parallel the Refinery’s existing hurricane levee and East 

Hardee Road within the proposed terminal. No additional clearing would be necessary outside the 

proposed terminal site for construction. 

Bayou Casotte Energy would use an NGL extraction system to ensure the natural gas from the 

proposed terminal is compatible with the interstate system (heat content or BTU content). NGL 

extraction reduces the BTU content by removing a portion of the hotter-burning NGLs (for example, 

propane and ethane) from the original LNG. The extraction system would be located within the proposed 

terminal site. 

The NGL extraction system would require a 12-inch-diameter pipeline interconnect to transport 

the NGL to the Tri-States NGL pipeline. The proposed NGL interconnect would parallel the proposed 

Gulfstream interconnect spur, then turn north to parallel the existing Gulfstream pipeline within its 

existing right-of-way. North of Longstreet Road, the NGL interconnect would continue west along the 

MPC right-of-way to the proposed tie in with the Tri-States NGL line via a meter station located at 

MP 4.3. Impacts related to the clearing of the right-of-way are addressed as part of the Gulfstream 

interconnect, and clearing of additional right-of-way would not be necessary for the construction of the 

NGL interconnect. A permanent right-of-way containing non-woody vegetation would be maintained 

above the pipeline to allow for future inspection and maintenance. 

Based on our review of information on the nonjurisdictional facilities provided by Bayou Casotte 

Energy, as well as reconnaissance of the general location where these facilities would be sited, we believe 

environmental impact associated with these nonjurisdictional facilities would be minimal. However, to 

ensure that potential issues are adequately addressed, we recommend that:

• Bayou Casotte Energy file with the Commission prior to construction the following 

information on nonjurisdictional facilities, including the MPC transmission lines and 

substation, the Refinery berth relocations, and the NGL extraction and pipeline system: 

a. final routing and design information, including a map depicting the location of 

the facilities; 

b. documentation of consultations with the appropriate agencies and the status of 

federal, state, or local permits or approvals required for construction; and 

c. status and copies of agency clearances (or copies of any surveys and reports 

prepared) for wetlands, threatened and endangered species, and cultural 

resources. 

2.3 LAND REQUIREMENTS 

Table 2.3-1 summarizes the land requirements for the facilities associated with the Casotte 

Landing Project. A detailed discussion of land requirements is presented in Section 4.7. 

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TABLE 2.3-1 

Summary of Land Requirements Associated with the Casotte Landing Project Pipeline 

Facility 

Land Affected During 

Construction (acres) 

Land Affected During 

Operation (acres) 

LNG Terminal 

 Wetlands 119.3 119.3 

 Open Water 25.1 25.1 

 Roads 0.0 0.0 

 Commercial/Industrial Space 115.0 115.0 

LNG Terminal Subtotala 259.4 259.4 

Pipeline and Associated Aboveground Facilities 

 Pipeline Right-of-Wayb & Lateral Pipelinesc 14.6 6.1 

 Meter Station (Interconnect Laterals) 1.5 0.9 

 Meter Station (Interconnect Spur) 1.3 0.9 

 Additional Temporary Workspaces 0.0 0.0 

 Roads 0.0 0.0 

Pipeline and Associated Aboveground Facilities Subtotal 17.4 7.9 

Nonjurisdictional Pipeline and Facilities

 Circulation Water Systems 7.9 0.0 

 NGL Pipeline 27.1 0.2 

 Meter Station (NGL Interconnect Pipeline) 1.2 0.7 

 Mississippi Power Transmission Line 0.0 0.0 

 Nonjurisdictional Pipeline and Facilities Subtotal 36.2 0.9 

Nonjurisdictional Pipeline and Facilities Subtotal 

Total 313.0 268.2 

____________ 

a

 Including the LNG storage tanks, buildings, process areas, utility area, boil-off gas compressor, meter skid, electrical 

substations, spill containment components, open space, and piping. 

b Based on a 110-foot-wide construction right-of-way during collocation of pipelines and an 85-foot-wide construction right-ofway during single occurrence. During operation, all proposed pipelines would be within existing rights-of-way. 

c

 Includes acreages of the Destin, Chandeleur (2), and Gulf South laterals. Based on an 85-foot-wide construction right-of-way. 

During operation, all proposed pipelines would be within existing rights-of-way.

2.3.1 LNG Terminal Facilities 

The proposed LNG terminal would be located on a 259.4-acre site adjacent to Bayou Casotte. 

The majority of this parcel consists of previously disturbed and developed industrial areas, which include 

119.3 acres of wetlands, 115.0 acres of existing industrial space, and 25.1 acres of open water (see 

Table 2.3-1). 

Existing access roads would be sufficient for proposed terminal operations, and no modification 

or addition of existing roadways would be needed. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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2.3.2 Pipeline and Associated Aboveground Facilities 

Construction of the pipeline interconnect facilities would disturb a total of about 17.4 acres of 

land. Of this total, 14.6 acres would be disturbed by the pipeline construction rights-of-way. Bayou 

Casotte Energy proposes to use a 150-foot-wide right-of-way for construction of the Gulfstream 

interconnect spur where it is collocated with the nonjurisdictional NGL pipeline. Where only one 

pipeline is located, a right-of-way width of 100 feet would be used (see Figures 2.3.2-1 through 2.3.2-4). 

An additional 1.5 acres would be disturbed by the four lateral pipelines. Approximately 17.4 acres would 

be required for construction with 6.1 acres for operation of the proposed pipeline interconnects. 

Following construction, areas of temporary workspace, and areas outside the existing permanent right-ofway would be allowed to revert to pre-construction conditions. 

2.4 CONSTRUCTION PROCEDURES 

This section describes the general procedures proposed by Bayou Casotte Energy for construction 

of the proposed LNG terminal and pipeline interconnect facilities. Refer to Section 4.0 for more detailed 

discussions of proposed construction and restoration procedures as well as additional measures that we 

have recommended to mitigate potential environmental impacts. 

The proposed LNG terminal and natural gas pipeline interconnects would be designed, 

constructed, operated, and maintained in accordance with federal safety standards that are intended to 

ensure adequate protection for the public and to prevent LNG and natural gas pipeline accidents or 

failures. 

Under the provisions of the Natural Gas Pipeline Safety Act of 1968, as amended, Bayou Casotte 

Energy would design, construct, operate, and maintain the LNG terminal facilities in accordance with the 

DOT’s Liquefied Natural Gas Facilities: Federal Safety Standards (49 CFR 193). The facilities would 

also meet the National Fire Protection Association (NFPA) Standards for the Production, Storage, and 

Handling of LNG (NFPA 59A). These standards specify siting, design, construction, equipment, and fire 

protection requirements for new LNG facilities. The carrier unloading facilities and any appurtenances 

located between the LNG carriers and the last valve immediately before the LNG storage tank would 

comply with applicable sections of the Coast Guard regulations in Waterfront Facilities Handling 

Liquefied Natural Gas (33 CFR 127) and Executive Order 10173. Process piping from tank top to grade 

would be installed in accordance with applicable American National Standards Institute (ANSI), 

American Society of Mechanical Engineers (ASME), and API standards. 

The proposed pipeline facilities would be designed, constructed, operated, and maintained in 

accordance with DOT regulations in Transportation of Natural and Other Gas by Pipeline: Minimum 

Federal Safety Standards (49 CFR 192). Among other design standards these regulations specify pipeline 

material selection; minimum design requirements; protection from internal, external, and atmospheric 

corrosion; and qualification procedures for welders and operations personnel. In addition, Bayou Casotte 

Energy would comply with the siting and maintenance requirements in 18 CFR 380.15 and other 

applicable federal and state regulations. 

In order to control and minimize runoff from the terminal site to Bayou Casotte during 

construction, Bayou Casotte Energy would implement it’s Upland Erosion Control, Revegetation, and 

Maintenance Plan (Bayou Casotte Energy’s Plan), as modified in this EIS (see Section 4.2.1). To 

minimize the potential for impacts to water quality, open-cut crossings would be accomplished in 

accordance with Bayou Casotte Energy’s Wetland and Waterbody Construction and Mitigation 

Procedures (Bayou Casotte Energy’s Procedures), as modified in this EIS (see Section 4.3.3). Bayou 

Casotte Energy’s Plan and Procedures are included in Appendix B. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Figure 2.3.2-1 

Proposed Casotte Landing Project 

Typical Pipeline Construction Right-of-Way Cross Sections 

2-21

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Figure 2.3.2-2 

Proposed Casotte Landing Project 

Typical Pipeline Construction Right-of-Way Cross Sections 

2-22

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Figure 2.3.2-3 

Proposed Casotte Landing Project 

Typical Pipeline Construction Right-of-Way Cross Sections 

2-23

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Figure 2.3.2-4 

Proposed Casotte Landing Project 

Typical Pipeline Construction Right-of-Way Cross Sections 

2-24

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
2-25

Bayou Casotte Energy has prepared a Stormwater Pollution Prevention Plan (SWPPP) that 

identifies potential sources of pollution and the Best Management Practices (BMP) to use to prevent and 

monitor potential impacts during construction (see Appendix C). In addition, Bayou Casotte Energy has 

prepared a Spill Prevention, Containment and Countermeasure Plan (SPCC Plan) for both the LNG 

terminal and pipeline interconnect portions of the Project to protect against the possibility of an 

inadvertent spill of hazardous materials during construction. The SPCC Plan addresses potential spills of 

fuels, lubricants, and other hazardous materials and describes spill prevention practices, spill handling and 

emergency notification procedures, and training requirements (see Appendix D). 

2.4.1 LNG Terminal Facilities 

2.4.1.1 Site Preparation 

Site preparation for the proposed LNG terminal (marine and storage facilities) would include 

general site stripping and cutting/filling to finished grade elevation, excavation and dredging of the slip, 

and construction of the perimeter levee around the LNG storage tanks. The perimeter hurricane levee 

would be constructed using the excavated material from the site. Bayou Casotte Energy would install 

temporary erosion and sediment controls at the outset of land disturbance activities, and maintain these 

controls until the completion of construction activities and the installation of permanent erosion control 

measures. 

Excavation - Stripping and Cutting 

Bayou Casotte Energy would strip and excavate high areas to level the site to a finished grade 

elevation of approximately 10 feet National Geodetic Vertical Datum (NGVD). The stripped and 

excavated material would be used onsite for the creation of the hurricane levee, ditches, and berms. 

Excavation and Dredging of the Marine Terminal 

Construction of the new marine terminal would require excavation and dredging at the proposed 

LNG terminal site for the slip along Bayou Casotte. Construction of the slip would begin by excavating 

the top 14 feet of overburden down to or near the water table. The total quantity of dry materials that 

would be excavated from the slip is estimated to be approximately 1.0 million cubic yards (mcy). This 

material would be used for fill, site leveling, and construction of the hurricane levee at the terminal site. 

Following excavation of the dry materials, dredging would begin from the edge of the Bayou 

Casotte into the slip area and then proceed inland. The total dredged volume at the marine terminal 

would be approximately 3.5 mcy and would extend to a depth of 46 feet below MLLW, which 

encompasses a 42 foot design depth, 2 feet of advanced maintenance, and an additional 2 feet of over 

depth (consistent with COE standards for dredged channels within this waterway system). 

Annual maintenance dredging of the marine slip would be required to ensure that the LNG 

carriers and crude tankers would continue to access the proposed terminal facilities. It is estimated that 

250,000 yd3

 of material would be removed annually for maintenance dredging. 

Since late 2005, Bayou Casotte Energy has been working with the regulatory and resource 

agencies to identify a site where it would place the materials dredged from the marine terminal. In its 

Section 103 evaluation included in its Joint Permit application to the COE, Bayou Casotte Energy listed 

the preferred placement option for the dredge material as a combination of placement at the EPA’s 

Pascagoula Ocean Dredged Material Disposal Site (ODMDS), located offshore in the Gulf of Mexico 

south of Horn Island; and approved and available federal and state coastal or offshore beneficial use (BU) 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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project sites. Currently, no BU project sites are available for the placement of dredged materials; 

therefore, the Pascagoula ODMDS site remains the proposed location for dredged materials placement 

during initial construction of the proposed marine terminal and for maintenance dredged materials. 

However, final Agency approvals have not yet been obtained. See Appendix E for the text of Bayou 

Casotte Energy’s Section 103 evaluation and Dredged Material Management Plan (DMMP). 

Figure 2.4.1-1 illustrates the location of the Pascagoula ODMDS in relation to the proposed 

terminal site. See Section 3.0 for a more detailed description of the potential BU sites and other dredged 

material placement alternatives. 

Based on the relatively long distance between the proposed LNG terminal site and the proposed dredged 

material placement area, mechanical dredging technology was selected over hydraulic dredging. The 

sediments would be removed using a clamshell dredge and would be placed in barges or scows for 

transport to the ODMDS. The bottoms of the barges or scows would be designed to open, thereby 

depositing the sediment in the placement area. The production rate of a mechanical dredging operation is 

dependent on a variety of factors, including sediment characteristics, bucket size, and the efficiency of 

exchanging the barges/scows. Dredging activities would occur on a 24-hour basis, seven days per week 

and would require about six months to complete. In addition, Bayou Casotte Energy would coordinate its 

dredging activities with the Coast Guard, the Pilots, and the COE to minimize shipping impacts. 

Hurricane Levee 

An earthen hurricane levee would surround the proposed LNG storage tanks and process area. 

The hurricane level would function as protection for the facility from hurricane storm surge, as well as 

provide secondary containment for the three proposed LNG storage tanks. The hurricane levee would 

have a finished top elevation approximately 14 feet above grade (22.8 feet NGVD). The walls would be 

sloped at approximately 2H:1V. Design engineering determining the volume of excavated material from 

the proposed marine berth and terminal site to construct the hurricane levee is currently in process. 

2.4.1.2 Material and Equipment Delivery 

Construction of the proposed LNG terminal would require many types of equipment and 

materials. Tagged equipment, instrumentation, and valves would be procured during the engineering 

phase of the Project and shipped to the site to meet requirements specified by the construction schedule. 

Additional items that would be shipped include piling, piping, structural steel, and electrical 

components. 

Fabrication shops and assembly areas would be used to fabricate structural steel components and 

other prefabricated units, as well as skid-mounted process equipment modules. These items would be 

delivered to the site in accordance with the construction schedule. A concrete batch plant would be 

located at the proposed terminal site to provide concrete for construction needs. 

Material and equipment requiring marine transport would be delivered to an appropriate existing 

local port (Pascagoula, Mobile, or New Orleans). The material and equipment would be unloaded if final 

transportation to the site is by road, or transferred onto barges if the equipment or material is delivered to 

the terminal site using marine transport. Unloading construction materials and equipment at the proposed 

LNG terminal site would be accomplished by the most suitable means, either by crane or forklifts. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Page 2-27 

Figure 2.4.1-1 Proposed Casotte Landing Project 

Dredged Material Placement Location 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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2.4.1.3 Marine Facilities 

The marine terminal would consist of an unloading slip with two berths to allow docking of an 

LNG carrier and a crude tanker simultaneously. Installation of waterside facilities would begin following 

excavation and dredging of the slip using a conventional heavy-lift derrick barge, which is typical of 

similar construction activities along waterways in the region. Supply barges would deliver materials to 

the crane barge and also would be used to store the materials until needed for construction. The crane 

barges would be used to lift beams and other materials into place. A barge-mounted heavy-lift crawler 

crane would be used for lifting piles into place so that they can be driven. Appropriately sized tugs and 

crew boats would be used, as required. 

Construction of the unloading berth would generally follow the sequence described below. 

Prefabrication of Process Area and Marine Berth Components 

Prefabrication of the main components for the process area and marine berth would involve the 

piles for the waterside facilities and supporting foundations. Piles for the supporting foundations would 

be either pre-cast type or pipe piles. All piles would be manufactured off site. Prefabricated piles would 

also be used to support the foundation of berth structures. A heavy lift derrick barge would be used to 

place the jackets in position, and the piles would be driven through the legs of the jacket. Bayou Casotte 

Energy currently plans to drive the steel pipe or concrete piles to design penetrations. The piles would 

range in length from 100 to 140 feet in length and 16 to 48 inches in diameter. 

Berth and Unloading Facilities 

The unloading platform, breasting and mooring dolphins, and access trestle would consist of 

reinforced concrete structures on piles. The dock pile caps and beams would be cast-in-place reinforced 

concrete structures, supported from the steel pipe piles with pile clamps, hangers, and soffit beams. The 

dock pile caps would be connected to the piles using a reinforced concrete plug extending into the pile 

top. The concrete deck slabs would then be installed using precast and cast-in-place reinforced concrete. 

Dolphin pile caps would then be installed for the mooring and breasting dolphins of the berth. 

The mooring and breasting dolphin pile caps would include mooring hooks for spring lines to provide 

greater flexibility in mooring various types of vessels, and fenders suitable to safely restrain the carriers 

from wind, current, and other forces while berthed at the marine terminal. 

The marine unloading and vapor return arms would then be lifted and set on the berth deck for 

installation. Once the arms are installed, the mezzanine platform, walkway and walkway supports, access 

trestles, structural steel supports, and remaining dock equipment (for example, firewater monitors and 

switchgear buildings) would be installed along with all related pipe work, electrical work, and 

instrumentation. 

2.4.1.4 LNG Storage Facilities 

Most of the major equipment related to the cryogenic systems for the proposed LNG terminal 

would require specialized materials and construction techniques. As a result, most, if not all, of the major 

facilities (including the LNG tanks and LNG unloading facilities) would be prefabricated offsite at 

specialty manufacturing and prefabrication sites. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Prefabrication of Tank Components 

Prefabrication of the main tank components would include the following: 

• nine percent nickel steel inner container shell and bottom plates; 

• internal tank accessories, nozzles, and roof structure components; 

• carbon-steel roof plates; 

• piping, ladders, platforms, and other structural elements; and 

• steel reinforcement for the foundation and outer concrete container and roof. 

Tank Construction 

The process of constructing the LNG tanks would generally proceed as follows: 

• the tank area would be filled, consolidated, and graded to the required level for the piling 

operations to be undertaken; 

• piles would be installed and prepared to connect the elevated slab; 

• construction of the post-tensioned secondary outer concrete tank wall; 

• construction of the steel dome roof and suspended decks; 

• installation of the steel reinforcement and concrete covering of the steel dome roof; 

• installation of the vapor barriers, the nine percent nickel steel secondary bottom, and the 

concrete leveling screed; 

• installation of the nine percent nickel steel inner container annular and bottom plates; 

• erection of the inner tank shell; 

• installation of internal tank accessories, piping, roof platforms, and walkways; 

• hydrostatic testing of the inner tanks and pneumatic testing of the outer tanks (see discussion 

below); and 

• installation of the insulation systems between the inner and outer tanks. 

The inner container of the LNG storage tanks would be hydrostatically tested in accordance with 

the requirements of API 620. The hydrotest water would be supplied only from an acceptable source, 

such as treated wastewater from the refinery or appropriately treated water from Bayou Casotte. This 

procedure would be approved by the Mississippi Department of Environmental Quality (MDEQ) before 

hydrotesting is conducted. Test water would be sampled and tested for suitability prior to use, in 

accordance with MDEQ requirements, procedures, and approvals. Approximately 28 million gallons of 

water would be required to test up to the required test level. Ideally, test water would be transferred 

between tanks and ultimately discharged into the Bayou Casotte Channel upon completion of the tests. 

Prior to discharge, the water would be tested again, in accordance with MDEQ requirements, procedures, 

and approvals to determine whether treatment is required and to establish an appropriate treatment 

method. Specific procedures would be developed for treating the water prior to discharge (for example, 

filtration, oil/water separators, clarifiers/ solids separators, activated carbon adsorption units, or chemical 

injection). 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Each tank would also be pneumatically tested at a pressure of 1.25 times the design pressure for 

one hour in accordance with API 620. The pneumatic test would be performed using dry air compressors 

for pressurization. 

Construction of Other Facilities 

Construction of the foundations, pipe racks, and terminal buildings together with installation of 

major mechanical equipment, process and utility piping, and electrical and instrumentation would occur 

once tank construction is underway. These facilities would be completed and pre-commissioned in 

readiness for mechanical completion of the LNG tanks. Piping systems would be tested using hydrostatic 

or pneumatic testing. In general, cryogenic piping would be pneumatically tested with dry air or nitrogen 

at 1.1 times design pressure. Piping other than cryogenic piping would be hydrotested using clean water 

at 1.5 times design pressure. Testing would be performed in accordance with ASME B31.3. 

As the construction of the process portion of the proposed LNG terminal progresses, work would 

commence on instrumentation and electrical loop testing and pre-commissioning activities, such that 

these activities would be completed concurrent with the completion of the tanks and ready for nitrogen 

purging. 

Restoration 

Areas of the proposed LNG terminal site that would be temporarily disturbed by construction of 

the proposed facilities would be stabilized with temporary erosion controls until construction is 

completed. Unless covered by equipment, gravel, or other covering, LNG terminal site areas would be 

seeded to establish revegetation in accordance with Bayou Casotte Energy’s Plan, as modified in this EIS. 

2.4.2 Pipeline Interconnects and Associated Aboveground Facilities 

Construction of the proposed natural gas pipeline interconnects would primarily involve standard 

pipeline construction techniques described in Section 2.4.2.1. Special construction techniques would also 

be used when constructing the pipeline across wetlands, waterbodies, roads, and foreign pipelines. These 

special construction techniques are described in Section 2.4.2.2. Construction of the aboveground 

facilities associated with the pipeline is discussed in Section 2.4.2.3. 

Pipeline construction workers would primarily use existing highways and roads that intersect the 

right-of-way for construction access. Bayou Casotte Energy does not anticipate that any new roads would 

be required during pipeline construction. However, some of the existing roads may require modifications 

or improvements to accommodate the weight and dimensions of construction equipment and materials. If 

any modifications or improvements would be required, Bayou Casotte Energy would be required to 

obtain the necessary approvals. 

Bayou Casotte Energy has indicated that it would use a laydown area located within the proposed 

terminal site that would have road access. 

2.4.2.1 General Pipeline Construction Techniques 

Figure 2.4.2-1 shows the typical steps of cross-country pipeline construction. Standard pipeline 

construction proceeds in the manner of an outdoor assembly line composed of specific activities that 

make up the linear construction sequence. These operations collectively include survey and staking of the 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Figure 2.4.2-1 

Proposed Casotte Landing Project 

Typical Pipeline Construction Sequence 

2-31

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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right-of-way, clearing and grading, trenching, pipe stringing and bending, welding and coating, loweringin and backfilling, hydrostatic testing, and cleanup. 

Survey and Staking 

Before construction, Bayou Casotte Energy crews would survey and stake the centerline and 

exterior boundaries of the construction right-of-way. Drainage centerlines and elevations, road and 

railroad crossings, and any temporary extra workspaces (laydown areas or at stream crossings) would also 

be staked. The exterior boundary stakes would mark the limit of approved disturbance areas and would 

be maintained throughout the construction period. Utility lines would be located and marked to prevent 

accidental damage during pipeline construction. Bayou Casotte Energy would notify affected 

landowners, regulatory agencies, water development districts, and flood control districts before surveying 

and staking of the proposed route. 

Clearing and Grading 

Bayou Casotte Energy would clear the right-of-way of large obstacles such as trees, brush, and 

logs. Timber would be removed when necessary for construction purposes. Timber and other vegetative 

debris may be chipped for use as erosion-control mulch, burned, or otherwise disposed in accordance with 

applicable state and local regulations and landowner crossing agreements. Burning, if necessary, would 

be conducted in such a manner as to minimize the fire hazard and prevent heat damage to surrounding 

vegetation. The right-of-way would then be graded where necessary to create a reasonably level working 

surface to allow safe passage of construction equipment and materials. Bayou Casotte Energy would 

install temporary erosion control measures at this time. 

Trenching 

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

excavate a trench to a sufficient depth to provide a minimum 3-foot depth of cover. Due to the absence of 

consolidated bedrock near the surface, Bayou Casotte Energy does not anticipate the need for blasting. 

Depending on soil conditions, the top of the trench would typically be 18 feet wide and the bottom of the 

trench would typically be at least 12 inches wider than the diameter of the pipe, or a minimum of 4 feet 

wide. In unstable and saturated soils, the trench would be wider. 

Spoil material excavated during trenching operations would be temporarily piled to one side of 

the right-of-way adjacent to the trench. Where the pipeline route is adjacent to an existing pipeline, the 

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

to keep working equipment off of the operating pipeline. In these collocated sections, the topsoil would 

be stockpiled on the working side of the right-of-way, outside the construction equipment lane (see 

Figure 2.3.2-1). 

Pipe Stringing and Bending 

Either before or after trenching, sections of externally coated pipe (also referred to as joints) 

would be shipped to the pipe yard and then transported to the right-of-way by truck and placed or 

“strung” along the excavated trench in a single, continuous line, easily accessible to the construction 

personnel on the working side of the trench, opposite the spoil side. 

The pipe would be delivered to the construction right-of-way in straight joints. Some bending of 

the pipe would be required to allow the pipeline to follow natural grade changes and direction changes of 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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the right-of-way. Selected joints would be bent in the field by track-mounted hydraulic bending machines 

as necessary before welding. 

Welding and Coating 

After stringing and bending are complete, pipe sections would be placed on temporary supports 

adjacent to the trench. The ends would be aligned and welded together using multiple passes for a full 

penetration weld. Only qualified welders would be permitted to perform the welding. Welders and 

welding procedures would be qualified according to applicable ANSI, ASME, and API Standards. 

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

Casotte Energy would inspect all welds, both visually and radiographically (i.e., x-ray), and would make 

any necessary repairs. Following weld inspection, the previously uncoated ends of the pipe at the welds 

would be epoxy coated. The coating on the completed pipe section would be inspected and any damaged 

areas repaired. 

Lowering-in and Backfilling 

After welding and coating are completed, the pipe would be lowered into the trench by side-boom 

tractors. Before lowering the pipe, the trench would be inspected to ensure that it is free of rocks and 

other debris that would damage the pipe or the coating. In addition, the pipe and trench would be 

inspected to ensure that the configurations of the pipe and trench configurations are compatible. 

Bladed equipment or a specially designed backfilling machine would be used to backfill the 

trench. No construction debris, including wooden supports, welding rods, containers, brush, trees, or 

refuse of any kind, would be permitted in the backfill. If rocks or other materials that would damage the 

pipe or coating are present in the backfill, a padding machine would be used to separate the rock from the 

backfill. In some instances, clean fill or additional protective coating such as rock shield would be placed 

around the pipe before backfilling. 

Segregated topsoil, where applicable, would be replaced after backfilling the trench with subsoil. 

Following backfilling, a small crown of material would be left to account for any future soil settling that 

might occur. 

Hydrostatic Testing 

After backfilling, Bayou Casotte Energy would hydrostatically test the pipeline in accordance 

with DOT regulations to ensure that the system is capable of operating at the design pressure. The testing 

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

specified amount of time. If a leak or break in the line were to occur during testing, Bayou Casotte 

Energy would repair and retest that section of pipe until DOT specifications are met. 

Bayou Casotte Energy estimates that approximately 450,000 gallons would be required to 

hydrostatically test the pipeline interconnects. The hydrotest water would be supplied only from an 

acceptable source, such as treated wastewater from the refinery or appropriately treated water from Bayou 

Casotte. This procedure would be approved by the MDEQ before hydrotesting is conducted. Test water 

would be sampled and tested for suitability prior to use, in accordance with MDEQ requirements, 

procedures, and approvals. Any leaks that are detected would be repaired and the pipeline segment 

retested. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Cleanup and Restoration 

After the pipeline interconnects have been installed, backfilled, and successfully tested, the rightof-way, temporary extra workspaces, and other disturbed areas would be permanently restored. Also, 

scrub-shrub and emergent wetlands would be restored to original contours and hydrological patterns, open 

space would be re-seeded according to NRCS recommendations, commercial/industrial land would be 

restored to pre-construction elevations, and the original surface cover would be restored. 

The restored construction right-of-way would be revegetated in accordance with Bayou Casotte 

Energy’s Plan (and requested variances, should they be approved), other permit requirements, and sitespecific landowner requests. Turf, ornamental shrubs, and other landscaping material would be restored 

in accordance with landowner agreements. 

2.4.2.2 Special Pipeline Construction Techniques 

Construction across wetlands, waterbodies, roads, and foreign pipelines may require special 

construction techniques. These techniques are described below. 

Wetland Crossings 

Construction of pipeline interconnects across wetlands would be in accordance with Bayou 

Casotte Energy’s Procedures, as modified in this EIS (see Section 4.3). During crossing of unsaturated 

wetlands (wetlands without standing water or saturated soils), construction would primarily be similar to 

the upland construction described above. Bayou Casotte Energy has requested the use of wetland 

construction rights-of-way that exceed 75-feet in width. As described in Section 4.4.4.2, we have denied 

this blanket request. Any proposed expansion of the construction right-of-way associated with 

waterbodies or wetlands must first be approved in writing by the Commission on a site-specific basis 

prior to construction. 

Woody vegetation would be cut off at ground level and removed from the wetlands leaving the 

root systems intact. 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, and would 

be maintained until revegetation is complete. Timber mats or terra mats would be used where necessary 

to stabilize the right-of-way for equipment, minimize rutting, and prevent the mixing of topsoil and 

subsoil. The pulling of stumps would not be permitted except in the area of the pipeline trench and in 

other areas where their removal is necessary for safety reasons. 

In accordance with Bayou Casotte Energy’s Procedures (as modified in this EIS), topsoil would 

be stripped over the trench line to a maximum depth of 12 inches in unsaturated soils and placed in a 

separate spoil pile. Following installation of the pipe, the trench would be backfilled and the topsoil 

replaced. Trench plugs would be installed as necessary to maintain wetland hydrology. The natural 

contours of the wetland would be restored, any required permanent erosion control measures would be 

installed, and the area would be temporarily stabilized with appropriate vegetation to protect the wetland 

soil from erosion. Materials such as timber mats placed in wetlands during construction would be 

removed during final cleanup. 

Waterbody Crossings 

Bayou Casotte Energy proposes to install the proposed pipeline interconnects across two shallow 

artificial canals and the nonjurisdictional NGL pipeline across six waterbodies using open-cut crossing 

methods in accordance with Bayou Casotte Energy’s Procedures, as modified in this EIS (see 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Section 4.3.2.2). The open-cut construction method involves excavation of the pipeline trench across the 

waterbody, installation of the pipeline, and backfilling of the trench with native material with no effort to 

isolate flow from construction activities. Excavation and backfilling of the trench would be accomplished 

using backhoes or other excavation equipment operating from one or both banks of the waterbody. 

Bayou Casotte Energy would construct the pipeline across the waterbodies in accordance with applicable 

permits. Bayou Casotte Energy’s Procedures, as modified in this EIS, include requirements for 

preconstruction planning, environmental inspection, specific construction methods, sediment and erosion 

control, restoration, and post-construction maintenance. Intermittent streams that are dry at the time of 

crossing would be crossed using the conventional upland construction techniques described above. 

Road and Railroad Crossings 

The proposed interconnect spur and NGL pipeline would cross several roadways and a railroad. 

Generally, a conventional bore would be required to install the pipeline under primary roadways and 

railroads. This method would not result in any impacts on the road or railroad and would avoid trafficrelated disruptions. During an open cut crossing of a roadway, Bayou Casotte Energy would keep at least 

one lane of traffic open during construction. During the brief period when the road would be completely 

cut, steel plates would be available on-site to cover the open area to allow passage by emergency vehicles. 

Access would be maintained except for the limited periods required for installing the pipeline. 

Smaller, unpaved roads would be open cut where permitted by local authorities. The proposed 

pipelines would be buried to a depth of at least 5 feet below road surfaces and two to three feet below 

railroad crossings, depending on the strata. Pipelines would be designed to withstand anticipated external 

loadings and casings would be installed only where specifically required by permitting authorities. After 

construction, these roads and driveways would be restored. 

2.4.2.3 Associated Aboveground Facilities 

Interconnect Sites 

During installation of the interconnect sites, construction activities and storage of construction 

materials and equipment would be confined to the pipeline construction right-of-way or approved 

temporary workspace. Bayou Casotte Energy would dispose of debris and waste generated during the 

construction and all disturbed surface areas would be restored. 

Bayou Casotte Energy would excavate as necessary to accommodate the new reinforced concrete 

foundations for the new metering equipment, heaters, and buildings. Forms would be set, rebar installed, 

and the concrete poured and cured in accordance with applicable standards. Backfill would be compacted 

in place, and excess soil would be used elsewhere or distributed around the site to improve grade. 

Metering equipment would be delivered to the site by truck and unloaded using cranes, front-end 

loaders, or both. The metering equipment would be positioned on the foundations, leveled, grouted where 

necessary, and secured with anchor bolts. 

After installation, all meter station equipment would be hydrostatically tested, and all controls 

and safety equipment and systems, including emergency shutdown, relief valves, and gas and fire 

detection equipment, would be checked and tested, before being placed in service. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Pig Launcher and Receiver 

Since the interconnect sections are relatively short in length, no pigging facilities would be 

constructed in association with the proposed Project. Bayou Casotte Energy proposes to meet its DOT 

requirements for integrity management by hydrostatically testing the pipeline interconnects. The 

metering facilities would be constructed large enough to accommodate the installation of in-line 

inspection tools, referred to in the pipeline industry as pigs, if required in the future. 

Mainline Block Valves 

Block valves would be installed at the pipeline origination within the LNG terminal and within 

each interconnect site pipeline terminus. Bayou Casotte Energy would install these facilities using the 

same standards and requirements established for construction of its proposed interconnect sites and 

pipeline. 

2.5 CONSTRUCTION SCHEDULE 

No work would begin until all required permits and approvals are in place. Bayou Casotte 

Energy indicates that it may require at least 35 months to construct the proposed facilities. Construction 

and testing of the LNG tanks would require the most time. Construction of the pipeline and associated 

aboveground facilities would occur during the last six months of construction of the LNG terminal 

facilities. Bayou Casotte Energy hopes to be in-service during 2010. 

2.6 ENVIRONMENTAL COMPLIANCE INSPECTION AND MITIGATION MONITORING 

In preparing construction drawings and specifications for the proposed Project, Bayou Casotte 

Energy would incorporate mitigation measures identified in its application as well as requirements of 

federal, state, and local agencies. Contractors would also be provided copies of applicable environmental 

permits. 

Bayou Casotte Energy would employ Environmental Inspectors (EI) on each construction spread, 

who would be responsible for quality assurance and compliance with mitigation measures, other 

applicable regulatory requirements, and company specifications. The EIs would report directly to the 

Chief Environmental Inspector and would have stop-work authority. The EI’s duties as described in 

Bayou Casotte Energy’s Plan and Procedures, as modified in this EIS, would include ensuring 

compliance with environmental conditions attached to any FERC authorization and to other permits or 

authorizations and to Bayou Casotte Energy’s environmental designs and specifications. 

In addition, the FERC staff would conduct periodic inspections to monitor the Project for 

compliance with the Commission's environmental conditions. 

2.7 OPERATION AND MAINTENANCE PROCEDURES 

2.7.1 LNG Terminal Facilities 

Bayou Casotte Energy would operate and maintain its facilities in compliance with 49 CFR 

193.2503 and 193.2605 and Sections 11.3.1 and 11.5.2 of NFPA 59A, 33 CFR 127, and other applicable 

federal and state regulations. Before construction, Bayou Casotte Energy would prepare and submit for 

approval operation and maintenance manuals that address specific procedures for the safe operation and 

maintenance of the LNG storage and processing facilities. Bayou Casotte Energy would also prepare an 

operations manual that addresses specific procedures for the safe operation of the carrier unloading 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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facilities in accordance with 33 CFR 127.305. Operating procedures would address normal operations as 

well as safe startup, shutdown, and emergency conditions. 

All operations and maintenance personnel at the proposed LNG terminal would be trained to 

properly and safely perform their assignments. The terminal operators would be trained in LNG safety, 

cryogenic operations, and the proper operation of respective terminal control equipment. The operators 

would meet all the training requirements of the Coast Guard and other applicable regulatory entities. 

Bayou Casotte Energy would maintain a full-time maintenance staff to perform routine 

maintenance and minor overhauls at the LNG terminal. Major overhauls and major maintenance 

activities would be handled by trained and qualified contract personnel. All maintenance activities, 

including scheduled preventive and predictive maintenance and unscheduled maintenance, would be 

managed through implementation of Bayou Casotte Energy’s comprehensive Maintenance Management 

System. This system would maintain the Project while optimizing operational expenses. Necessary 

maintenance of the unloading slip would include the dredging of sediments that have accumulated within 

it. Bayou Casotte Energy anticipates that the unloading slip would need to be dredged every one to three 

years, depending on local sedimentation rates. According to preliminary modeling, maintenance dredging 

would include a volume of up to 250,000 m3

 per year. Agency consultation regarding placement of the 

dredged material is ongoing but is proposed for a combination of the Ocean Dredged Material Disposal 

Site (OSMDS) south of Horn Island and federal and state Beneficial Use project sites. 

2.7.2 LNG Carriers 

Although LNG vessels and their operation are directly related to the use of the proposed import 

terminal, they are not subject to the Section 3 authorization sought in this application. The LNG carriers 

arriving at the Casotte Landing LNG Terminal must comply with all federal and international standards 

regarding LNG shipping. A detailed discussion of design and safety features of LNG carriers is presented 

in Sections 2.1.2 and 4.12.5. 

2.7.3 Pipeline Interconnects and Associated Aboveground Facilities 

The pipeline interconnect facilities would be operated and maintained in accordance with 49 CFR 

192, Transportation of Natural and Other Gases by Pipeline: Minimum Federal Safety Standards, as

required by the DOT. Section 4.12.7 presents a discussion of the DOT’s safety regulations and 

requirements for natural gas pipelines and describes how Bayou Casotte Energy would meet these 

requirements. 

2.8 SAFETY CONTROLS 

2.8.1 LNG Terminal Facilities 

The proposed LNG terminal facilities would be sited, designed, constructed, operated, and 

maintained in compliance with federal safety standards. Federal siting and design requirements for LNG 

facilities are summarized in Table 2.8.1-1. 

2.8.1.1 Spill Containment 

The LNG impoundment systems for the terminal facilities would be designed and constructed to 

comply with DOT regulations (49 CFR 193, Sections 193.2149 through 193.2185). These regulations

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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require that each LNG container and each LNG transfer system be provided with a means of secondary 

containment that has been sized to hold the quantity of LNG that would result as a result of the design 

spill that is appropriate for the area and LNG equipment. The design spills are defined in NFPA 59A. 

TABLE 2.8.1-1 

Federal Siting and Design Requirements for LNG Facilities 

Federal Citation Requirement 

Thermal Radiation Protection (49 CFR 193.2057 and Section 

2.2.3.2 of NFPA 59A) 

Ensure that certain public land uses and structures outside the 

LNG facility boundaries are protected in the event of a LNG 

fire. 

Flammable Vapor-Gas Dispersion Protection (49 CFR 

193.2059 and Sections 2.2.3.3 and 2.2.3.4 of NFPA 59A) 

Prevent a flammable vapor cloud associated with a LNG spill 

from reaching a property line that can be built upon. 

Wind Forces (49 CFR 193.2067) All facilities must be designed to withstand wind forces of not 

less than 150 miles per hour without the loss of structural 

integrity. 

Impounded Liquid (Section 2.2.3.8 of NFPA 59A) Liquids in spill impoundment basins cannot be closer than 50 

feet from a property line that can be built upon or a navigable 

waterway. 

Container Spacing (Section 2.2.4.1 of NFPA 59A) LNG containers with capacities greater than 70,000 gallons 

must be located a minimum distance of 0.7 times the container 

diameter from the property line or buildings. 

Vaporizer Spacing (Section 2.2.5.2 of NFPA 59A) The integral heated vaporizers must be located at least 100 

feet from a property line that can be built upon and at least 50 

feet from other select structures and equipment. 

Process Equipment Spacing (Section 2.2.6.1 of NFPA 59A) Process equipment containing LNG or flammable gases must 

be located at least 50 feet from sources of ignition, a property 

line that can be built upon, control rooms, offices, shops, and 

other occupied structures. 

Marine Transfer Spacing (33 CFR 127.105) Each LNG unloading flange must be located at least 985 feet 

from any bridge crossing a navigable waterway. 

The LNG storage tanks would use a full-containment design, consisting of an inner nine percent 

nickel steel tank surrounded by a secondary outer concrete tank. The outer tank would be sized to contain 

100 percent of the full design volume of the tank in the event that there is a complete failure of the inner 

tank. 

LNG spilled from the secondary containment of the tanks (the piping), along with any other spills 

in the process area, would be directed to the main (process) impoundment basin through the use of spill 

pads and containment troughs. Any spill from the unloading arms, or occurring in the dock area, would 

drain into the jetty impoundment basin. In accordance with the requirements of NFPA 59A, each basin 

would be able to contain a 10-minute spill resulting from any single leakage source leading to it at the 

maximum unrestricted flow rate. 

2.8.1.2 Hazard Detection System 

Hazard detectors would be installed consisting of flame detectors, hazardous gas detectors, low 

and high temperature detectors, and smoke detectors. The hazard detection system is designed to provide 

operating personnel early detection of released flammable liquids and fires, to show the specific location 

of the release or fire, to initiate automatic equipment shutdowns, and to initiate the pre-programmed fire 

control systems. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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2.8.1.3 Hazard Control System 

A variety of fire suppression agents would be employed for fighting fires within the LNG 

terminal. The type of agent used in a specific situation would depend on the characteristics of a particular 

event and on the relative effectiveness of the various agents on that particular type of fire relative to either 

a specific unit of the plant design or operation. The types of fire suppression agents to be employed 

include: 

• fixed water spray or deluge systems; 

• fixed high expansion foam systems; 

• fixed dry chemical extinguishing systems; 

• clean agent extinguishing system release; 

• aqueous film forming foam; and 

• fire protection in buildings, generally consisting of smoke, fire, and gas detectors and 

portable fire extinguishers. 

The LNG terminal would be equipped with separate but integrated facility safety and control 

systems, consisting of a Safety Instrumented System (SIS), Fire and Gas Detection and Alarm System 

(F&GDAS), Human Machine Interface (HMI), Process Control System (PCS), and closed circuit TV 

system. The safety and control would notify personnel, both visibly and audibly, of a hazard at the 

facilities. The alarms will have both different colors and different sounds according to the hazard they 

represent. The SIS subsystem would allow for the safe shutdown and isolation of individual equipment 

items, and sections of the plant, depending on the particular incident. The F&GDAS subsystem would 

provide for plant-wide detection and protection from fire and hazardous gas leaks. Each end device (fire 

and gas detectors, suppressant release, and manual call points) will have individual indications as part of 

the F&GDAS Visual Display Units and operator interface. 

2.8.1.4 Firewater System 

The Terminal’s fire protection system would include aqueous film forming foam (AFFF) 

monitors and/or foam hose reel stations, dry chemical extinguishing systems, and 100-percent redundant 

fire protection water and foam supply systems. The firewater system would be powered by a combination 

of electric motors and emergency diesel-driven engines. The firewater supply would be from a fire water 

pond that serves both the Terminal and the Refinery. The fire protection system would comply with 

NFPA 59A and 49 CFR 193. 

Fresh water obtained from the municipal water system would be stored in an on-site fire water 

pond with a capacity to provide 24 hours of continuous pumping. The Terminal fire water system would 

be supplied by four dedicated 50 percent fire water pumps, with one of the two primary fire water pumps 

being electrically powered and the other being diesel driven. The two back-up fire water pumps would 

both be diesel driven. The fire water pumps would be capable of pumping 3,500 gpm each, at a discharge 

pressure of 175 psig. The fire water pond would be designed in accordance with NFPA 22 and API 620; 

the fire water pumps would be installed in accordance with NFPA 20. The fire water distribution system 

of the adjacent Refinery would serve as a secondary source of water in the event that it is needed. 

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2.8.1.5 Fail-Safe Shutdown 

The LNG terminal would have an emergency shutdown system through the SIS and the Fire and 

Gas Panel to allow for the safe termination of operations in the event of an operational problem. These 

systems would be equipped with automated shutdown devices to eliminate the need for manual 

intervention in the event of an emergency. The system would allow for either the shutdown of individual 

sections of the LNG terminal or the entire terminal depending on the particular incident. Sections of the 

LNG terminal that would be shut down individually would include the ship unloading operation or 

individual pieces of equipment. Alarms would be installed in the control room to notify operating 

personnel if a potentially hazardous condition is detected by the field hazard instrumentation. 

2.8.1.6 Security System 

Bayou Casotte Energy would install security provisions at the LNG terminal which could include: 

• a security fence around the LNG terminal property; 

• a curved road at the primary entrance to the LNG terminal to limit the speed of approaching 

vehicles; 

• a security gate for vehicles and pedestrians to access the LNG terminal; 

• a continuously staffed guardhouse at the main entrance to the LNG terminal; 

• continuous surveillance of the LNG terminal interior and terminal perimeter by strategically 

placed CCTVs that would be monitored from the plant’s control room; 

• safety and security training of all LNG terminal personnel; and 

• preparation of a security procedures and response manual in coordination with applicable 

federal, state, and local requirements. 

2.8.2 LNG Carriers 

The LNG carriers 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, SOLAS, as well as 46 CFR 154, which contains 

the United States regulations for implementing the International Gas Code. United States flag LNG 

carriers would be required to have a valid Coast Guard Certificate of Inspection; foreign flag LNG 

carriers would be required to possess a valid IMO Certificate of Fitness and a Coast Guard Certificate of 

Compliance. Both United States and foreign flag carriers must be inspected annually by the Coast Guard 

and the flag state. A Coast Guard Certificate of Inspection is required every two years. Further 

discussion of LNG carrier safety standards is included in Section 4.12.5. 

2.8.3 Pipeline and Associated Aboveground Facilities 

The pipeline and aboveground facilities associated with the Casotte Landing Project would be 

designed, constructed, operated, and maintained in accordance with DOT’s Transportation of Natural and 

Other Gas By Pipeline: Minimum Federal Safety Standards in 49 CFR 192. These safety standards are 

discussed in Section 4.12.7. 

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2.8.3.1 Corrosion Protection and Detection System 

A cathodic protection system would be installed to prevent or minimize corrosion and to mitigate 

alternating current interference from the overhead electric transmission lines. 

2.8.3.2 Emergency Response Procedures 

Pipeline system emergencies can include gas leaks, fires or explosions, and/or damage to the 

pipeline and aboveground facilities. In accordance with DOT regulations, Bayou Casotte Energy would 

develop an emergency response plan to address procedures to be followed in the event of an emergency 

along the pipeline. This plan would include training of employees on emergency procedures; establishing 

liaisons with appropriate fire, police, and other community officials; and informing the public on how to 

identify and report an emergency condition on the pipeline route. 

2.9 FUTURE PLANS AND ABANDONMENT 

Bayou Casotte Energy currently has no plans for future expansion of the facilities proposed in 

this application. 

The proposed Casotte Landing Project is designed for a 25- to 30-year life span. 

Decommissioning plans for the Project would be developed and are a component of the constructability 

design for the facility. Primary decommissioning involves the removal of all aboveground structures. 

Certain facilities below ground may be left in place after proper abandonment, if their removal would 

create adverse disturbance or impacts. All material that would not be reused/renovated would be properly 

disposed of in accordance with applicable regulations. Alternative decommissioning options would also 

be reviewed to determine the potential for reuse/recycle of equipment and renovation of the site for 

potential recreational, governmental, or industrial purposes. 

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3.0 ALTERNATIVES 

3.1 INTRODUCTION 

This EIS addresses alternatives to the proposed actions before both the FERC and the Coast 

Guard. The FERC must consider whether or not to approve the facilities proposed by Bayou Casotte 

Energy and to allow operation of the facilities. The proposed action before the Coast Guard is to consider 

whether of not to issue Bayou Casotte Energy an LOR finding the waterway suitable for LNG marine 

traffic with the conditions referenced in Section 2.0. The Coast Guard, with input from the Pascagoula 

AMSC, has completed an initial review of Bayou Casotte Energy’s WSA in accordance with the guidance 

in Coast Guard NVIC 05-05. 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. 

The WSA itself is designated Sensitive Security Information as defined in 49 CFR Part 1520. Because 

any unauthorized disclosure of these details could be employed to circumvent the proposed security 

measures, they are not releasable to the public. 

As a result of this review, the Coast Guard advised the FERC by letter dated April 1, 2006, that 

the Pascagoula Bar, Horn Island Pass, Lower Pascagoula, and Bayou Casotte Channels can accommodate 

the LNG marine traffic associated with the project. The letter stated that these waterways can 

accommodate the proposed traffic and there is sufficient capability within the port community to 

responsibly manage the safety and security risks of this project. In a follow-up letter to the FERC dated 

September 5, 2006, the Coast Guard clarified that the April 1, 2006 letter gave a preliminary evaluation to 

meet the recommendations of NVIC 05-05. The September 5 letter also stated that any final 

determination of waterway suitability is contingent upon an evaluation of certain conditions including 

those identified in Section 2.0. With the completion of this final EIS, the Coast Guard will complete its 

review and issue an LOR to address the suitability of the waterways for LNG transport. 

A typical LOR would address the suitability of navigation channels in the Port of Pascagoula for 

LNG ship transit; it would not constitute a final authority to commence LNG operations. The Coast 

Guard’s LNG Vessel Transit Management Plan would be developed in conjunction with state and local 

law enforcement and emergency response communities. In addition, under 33 CFR 165 the Coast Guard 

may establish a moving safety zone during LNG vessels’ transit of the waterway, including requirements 

for daylight transit and one way LNG vessel traffic on the waterway, and for another safety zone around 

the LNG facility when the LNG vessels are moored. Only personnel or vessels authorized by the COTP 

are permitted within these zones. 

In accordance with NEPA and the FERC policy, we evaluated a number of alternatives to the 

proposed Casotte Landing Project, to determine whether they would be reasonable and environmentally 

preferable to the proposed action. These alternatives included the no action or postponed action 

alternatives, system alternatives, LNG terminal site alternatives, LNG terminal design alternatives, 

pipeline interconnect alternatives, and dredge material placement alternatives. Identification of 

alternatives to the proposed Project incorporated public comments and input received from federal and 

state regulatory agencies and other interested parties. 

As described in Section 1.1, the primary purpose of the Casotte Landing Project is to provide an 

additional source of firm, long-term, and competitively priced natural gas to the southeast and the broader 

United States markets by accessing natural gas reserves throughout the world. More specifically, Bayou 

Casotte Energy indicates that its specific objectives for the proposed Project are to construct and operate 

an LNG terminal and associated pipeline facilities with the capability to: 

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• access gas markets primarily in the southeastern United States, as well as the Mid-Atlantic 

and New England regions, through interconnects with existing intra- and interstate pipeline 

infrastructure; 

• provide vaporization facilities to accommodate the send-out of natural gas all year at a 

nominal rate of approximately 1.3 Bcfd; 

• provide LNG storage facilities with a combined capacity of at least 480,000 m3

; 

• provide facilities needed to receive and unload a range of LNG carriers from approximately 

125,000 m3

 to 200,000 m3 capacity1, while making use of an existing 42-foot-deep shipping 

channel; 

• start-up terminal operations by 2010; 

• be located proximal to existing NGL infrastructure and markets for the sale of associated 

liquids; 

• provide synergies with other existing Chevron owned businesses; and 

• provide Bayou Casotte Energy sufficient control and proprietary rights of operation to ensure 

operability for a 25- to 30-year project life. 

The identified potential alternatives were evaluated and compared to the proposed Casotte 

Landing Project to determine whether they would be technically and economically feasible and practical; 

offer significant environmental advantage over the proposed Project; and meet the objectives of the 

proposed Project, as listed above. With respect to the first criteria, it is important to recognize that not all 

conceivable alternatives are technically and economically feasible and practical. Some alternatives may 

be unfeasible because they are unavailable and/or incapable of being implemented after taking into 

consideration costs, existing technologies, and logistics in light of the overall project purpose. In 

conducting a reasonable analysis, it is also important to consider the environmental advantages and 

disadvantages of the proposed action and to focus the analysis on those alternatives that may reduce 

impacts and/or offer a significant environmental advantage. 

By consistently applying evaluation criteria and comparing potential environmental affects, each 

alternative was considered until it was clear that the alternative was not reasonable or would result in 

significantly greater environmental impacts that would not be readily mitigated. Those alternatives that 

appeared to be the most reasonable with less than or similar levels of environmental impact are reviewed 

in the greatest detail. 

3.2 NO ACTION OR POSTPONED ACTION ALTERNATIVE 

The FERC has three alternative courses of action in processing an application for a Certificate. It 

may: 1) deny the Certificate; 2) postpone action pending further study; or 3) grant the Certificate with or 

without conditions. Similarly, alternative courses of action to the Coast Guard proposed action include: 

1) issuance of a Coast Guard LOR finding the waterway not suitable for LNG vessel traffic (no action 

alternative); 2) postponing the issuance of a Coast Guard LOR pending further analysis and study; 3) 

issuance of a Coast Guard LOR finding the waterway suitable for LNG vessel traffic with conditions; and 

 

1 Bayou Casotte Energy indicates that the existing Bayou Casotte channel and associated navigational aids are 

currently only sufficient to accept LNG carriers up to approximately 160,000 m3 capacity, but the Casotte Landing 

Project as proposed has been designed with the flexibility to accommodate larger LNG carriers should the channel 

be modified at a future date to enable their passage. 

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4) issuance of a Coast Guard LOR finding the waterway suitable for LNG vessel traffic without 

conditions. 

As previously described in Section 1.1, projected natural gas demands in the United States 

markets are expected to exceed the currently available supply. The growth in natural gas demand is 

driven primarily by increased use of natural gas for electricity generation and industrial applications, 

which together account for 62 percent of the projected demand growth from 2004 to 2025 (EIA 2006). 

Bayou Casotte Energy believes that an additional supply of natural gas is necessary to satisfy this 

increasing demand. To maintain pace with growing energy demands, the EIA (2006) anticipates that 

consumption of natural gas in the United States will grow from 22.4 trillion cubic feet (Tcf) per year in 

2004 to 27.0 TCF in 2025. Similarly, current gas consumption in the southeastern United States 

(Alabama, Florida, Louisiana, Mississippi, and Georgia) is projected to increase from 4.0 Tcf per year in 

2003 to 4.7 Tcf per year by 2025, an annualized increase of 2.4 percent (EIA 2005). The proposed 

Project would supply up to 1.3 Bcfd of natural gas directly to the southeast and broader United States 

markets through interconnects with the existing interstate pipeline system. Bayou Casotte Energy 

believes that the addition of incremental supply at the proposed interconnect locations would help meet 

growing energy demands, enhance reliability, and result in supply diversification by accessing natural gas 

reserves from a variety of sources around the world, possibly including Angola, Nigeria, and Venezuela. 

If the FERC denies the application, the short- and long-term environmental impacts identified in 

this EIS would not occur. If the Commission postpones action on the application, the environmental 

impacts identified in this EIS would be delayed, or if the Applicant decided not to pursue the Project, the 

impacts would not occur at all. However, if the FERC were to select the no action or postponed action 

alternatives, the objectives of the proposed Project would not be met, and Bayou Casotte Energy would 

not be able to provide a new source of natural gas to markets that can be accessed through the proposed 

pipeline interconnects. 

Although it would be purely speculative and beyond the scope of this analysis to attempt to 

predict what actions might be taken by policymakers or end users in response to the no action or 

postponed action alternatives, it is likely that potential end users would make other arrangements to obtain 

natural gas service (e.g., traditional, non-LNG derived natural gas, or LNG-derived gas from another 

project), or make use of alternative fossil-fuel energy sources (e.g., fuel oil or coal), other traditional longterm fuel source alternatives (e.g., nuclear power or hydropower), and/or renewable energy sources, such 

as wind power, to compensate for the reduced availability of natural gas that would be supplied by the 

proposed Project. It is also possible that energy conservation practices would be used to offset the 

demand for natural gas in markets that would be supplied by the proposed Project. 

3.2.1 Alternatives to the Coast Guard Action 

For the Coast Guard’s proposed action, the no action alternative would be issuance of an LOR 

that finds the waterway not suitable for LNG marine traffic. Similar to the no action alternative of the 

FERC, the no action alternative for the Coast Guard would avoid any Project-related environmental 

effects in the waterway. However, the no action alternative would also prevent LNG carriers from 

delivering LNG to the proposed import terminal, and the objectives of the proposed Project would not be 

met. 

If the Coast Guard postpones issuance of an LOR pending further analysis and study, the effect 

would likely be similar to the FERC postponing its action. Postponing issuance of an LOR would lead 

Bayou Casotte Energy to delay the Project, thus postponing the potential environmental effects. 

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The preferred alternative is for the Coast Guard to issue an LOR finding the waterway suitable for 

LNG vessel traffic with conditions. These conditions include: 1) establishment of a moving safety zone 

during LNG vessels’ transit of the waterway, including requirements for daylight transit and one way 

LNG marine traffic on the waterway, as well as another safety zone around the LNG facility while the 

LNG vessels are moored; 2)an annual review of the facility’s Waterway Suitability Assessment by the 

applicant to evaluate if any conditions in the waterway have changed that would require issuance of a new 

LOR, with submittal of such annual reviews to the COTP for consideration and issuance of a new LOR, if 

required; 3) LNG marine traffic must navigate the waterway from the outer sea buoy to the berthing with 

harbor pilots onboard; 4) that tug assistance be provided as deemed necessary by the Pascagoula pilots; 5) 

that all LNG traffic make a SECURITE broadcast prior to crossing the Gulf Intracoastal Waterway; 6) 

implementation of a Coast Guard approved LNG Vessel Transit Management Plan; and 7) that adequate 

Coast Guard resources be available to implement the security measures described above. If these 

conditions to the LOR are imposed, the potential for accidental releases or releases resulting from terrorist 

attacks would be minimized. Considering this and the other potential environmental impacts discussed in 

this EIS, the total potential for adverse environmental impacts resulting from the Coast Guard’s proposed 

action is not considered significant. 

A reasonable alternative to the Coast Guard action of issuing an LOR that finds the waterway 

suitable for LNG vessel traffic with conditions is to issue an LOR finding the waterway suitable for LNG 

vessel traffic without conditions. Under this alternative, some of the adverse economic effects of the 

LOR conditions would be lessened. For example, costs to the Coast Guard or the Project applicant could 

be avoided if: 1) the cost to the Coast Guard for escort patrols would be avoided if the condition for 

establishment of a moving safety zone was not imposed; 2) the cost to the facility for development of 

additional Waterway Safety Assessments would be avoided if the condition requiring an annual 

Waterway Safety Assessment was not imposed; 3) the cost to the facility for harbor pilots boarding for 

the transit of LNG marine traffic from the outer sea buoy to the facility would be avoided if this condition 

was not imposed; 4) the cost to the facility for tug assistance would be avoided if this condition was not 

imposed; and 5) the cost to the Coast Guard for security patrols would be avoided if the condition for a 

safety zone around the facility was not imposed. However, the potential for adverse environmental 

effects would be greater if LOR conditions were not imposed. Specifically, there would be an increase in 

the potential for adverse environmental effects from collisions, allisions and terrorist threats if: 1) moving 

and stationary safety zones were not required; 2) Waterway Safety Assessments were not updated with 

the most current information on changes in the waterway; 3) a harbor pilot was not required aboard the 

LNG vessel while transiting the waterway; 4) tug assistance was not required while transiting the 

waterway and/or during docking; 5) a SECURITEE announcement was not required before crossing the 

Gulf Intercoastal Waterway; 6) an LNG Vessel Transit Management Plan was lacking; and 7) Coast 

Guard resources required to ensure implementation of the safety zones and other security measures were 

lacking. 

If an LOR is issued that determines the waterway is unsuitable for LNG vessel traffic, then the 

potential for additional adverse environmental impacts would be avoided, but this action would not 

provide the United States with LNG as an alternative energy source. If issuance of an LOR is delayed, 

any potential environmental impacts would also be delayed. However, this alternative would also delay 

providing the United States with an alternate source of energy. 

The preferred alternative of issuing an LOR with the referenced conditions would allow LNG 

vessel traffic to reach the proposed Project with a minimum of potential environmental impacts, and 

provide an alternate source of energy, which would supplement and/or replace the use of non-renewable 

energy sources such as coal and petroleum products, as well as renewable nuclear fuels. 

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3.2.2 Energy Source and Conservation Alternatives 

While traditional, non-LNG derived natural gas production is important to the overall supply of 

energy nationally, LNG imports will become increasingly important sources of natural gas for the United 

States (EIA 2006). Although domestic natural gas production, primarily from unconventional sources 

(e.g., shale, tight sands, and coal bed methane) and the Arctic, is expected to rise through about 2019, 

forecasts continue to indicate that domestic production will provide a decreasing share of total natural gas 

supply (EIA 2006). Likewise, net pipeline imports of natural gas from Canada and Mexico are also 

expected to continue to decline as a function of depletion and growth in Canada’s domestic consumption 

(EIA 2006). Failure to provide additional sources of natural gas to the domestic market would result in 

increased natural gas prices or shortages for industrial use and electricity generation. Alternative 

arrangements to obtain natural gas service would require the construction of modified or new LNG import 

or natural gas pipeline facilities in other locations. If such facilities were approved and constructed, each 

would result in its own set of specific impacts. The ability of other existing or proposed natural gas 

facilities to meet the objectives of the proposed Project are addressed in Section 3.3. 

Denying or postponing a decision on the Casotte Landing Project would result in reduced natural 

gas availability in the targeted market regions. Such shortages would in turn lead to an increased reliance 

on fuel oil and other non-renewable fuel supply sources for power generating facilities. However because 

petroleum product consumption is also projected to increase (EIA 2006), it is unlikely that fuel oil would 

provide a readily available or cost-effective alternative to natural gas. Further, natural gas is the cleanest 

burning of the fossil fuels. Relative to natural gas, reliance on coal or fuel oil to power electric generation 

would likely result in greatly increased emissions of pollutants, such as NOx SO2, CO and CO2, and 

associated reductions in air quality and global warming. Additionally, ash residues from the combustion 

of coal are caustic and must be disposed of in specialized landfills that prevent acidic runoff, caused by 

rain mixing with the ash, from leaching metals from the soil into the groundwater. These landfills take 

valuable lands out of use at significant costs. Conversely, natural gas combustion does not result in any 

residue. In addition, the handling and use of petroleum products has historically led to a greater 

occurrence of spills than the handling and use of LNG. Any spills of LNG would gasify, leaving no 

residue in water and soil. 

Other long-term fuel source alternatives to natural gas include nuclear power, hydropower, and 

the development of renewable energy sources. Although there has recently been renewed interest in 

nuclear power production, growth in nuclear generating capacity will only account for about 10 percent of 

total United States generating capacity by 2019, and is expected to remain at that level through 2030 (EIA 

2006). Radiation from nuclear fuel handling and use has a historically greater potential for adverse 

environmental impacts than the use of LNG. Spent nuclear fuel must be disposed of in specialized deep 

wells, with multiple safeguards to protect the environment. However, no such safeguards are required in 

association with natural gas usage. Additionally, regulatory requirements, cost considerations, and public 

concerns make it unlikely that new nuclear power plants would be sited and developed to serve the 

markets targeted by the proposed Project within a timeframe that would meet the objectives of the 

proposed Project. The EIA (2006) does not anticipate that any new nuclear power plants will begin 

operation before 2014. 

Renewable energy projects and energy conservation measures will likely play an increasingly 

prominent role in meeting the United States’ energy demands in the coming years. Though efficiency 

upgrades at existing hydropower facilities are expected to produce incremental additions of power 

production in the coming years, it is unlikely that new and/or significant sources of hydropower would be 

permitted and brought online as reliable, energy source alternatives to the proposed Project. Federal, 

state, and local initiatives will likely contribute to an increase in the availability and cost-effectiveness of 

non-hydropower renewable energy sources such as wind, solar, tidal, geothermal, and biomass. Even so, 

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the percentage of national electricity generated from non-hydropower renewable energy sources is only 

projected to increase to 3.2 percent by 2025 (EIA 2005), which would offset only a small part of the 

projected energy demands. 

Similarly, energy conservation would help alleviate some of the growing demand for energy and, 

therefore, offset some of the need for LNG supplies. The EIA (2006) expects that energy conservation 

will be induced by higher energy prices in the future. However, projections indicate that energy demand, 

primarily for natural gas, will continue to outpace programs designed to stimulate energy conservation. 

Although both renewable energy sources and energy conservation measures will be important elements in 

addressing future energy demands, they would not be able to meet more than a small fraction of that 

demand within the foreseeable future. Thus, renewable energy sources and energy conservation would 

not preclude the need for natural gas infrastructure projects like that proposed by Bayou Casotte Energy. 

In light of the preceding analysis, we do not recommend the no action or the postponed action 

alternative. 

3.3 SYSTEM ALTERNATIVES 

System alternatives would make use of other existing or proposed LNG or natural gas facilities to 

meet the objectives of the proposed Project. A system alternative would make it unnecessary to construct 

all or part of the proposed Project, although some modifications or additions to the existing or proposed 

facilities would be required to increase capacity. Although these modifications or additions would result 

in environmental impacts, the impacts would be less than, similar to, or greater than those associated with 

construction of the proposed Project. The purpose of identifying and evaluating system alternatives is to 

determine whether potential environmental impacts associated with the construction and operation of the 

proposed facilities would be avoided or reduced while still meeting the Project objectives. 

The analysis below examines the existing and proposed LNG and other natural gas systems that 

currently or would eventually serve the markets targeted by the Casotte Landing Project, and considers 

whether those systems would meet the proposed Project objectives while offering an environmental 

advantage over the proposed Project. Specifically, the system alternatives considered in our analysis 

include: 

• use of existing or planned onshore LNG terminals (Onshore LNG Terminal System 

Alternatives); 

• use of existing or planned offshore LNG terminals (Offshore LNG Terminal System 

Alternatives); and 

• use of existing or planned natural gas pipeline systems (Pipeline System Alternatives). 

To be considered viable, any system alternative to the proposed Project would need to provide 

LNG carrier unloading, storage, and sendout capacities similar to that proposed by Bayou Casotte Energy. 

Additionally, the system alternatives would need to provide access to the existing interstate pipeline 

infrastructure to serve the gas markets targeted by the Casotte Landing Project. 

3.3.1 Onshore LNG Terminal System Alternatives 

3.3.1.1 Existing Onshore LNG Terminals 

There are 16 existing LNG facilities currently under the FERC jurisdiction in the continental 

United States. Of these, 12 are peak-shaving plants that liquefy natural gas and store LNG during periods 

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of low natural gas demand (summer months) for later vaporization and sendout during higher demand 

periods (winter months). The remaining four facilities are baseload LNG import terminals that provide 

unloading, storage, and delivery services in the United States. These facilities are operated by Distrigas 

of Massachusetts LLC (Distrigas) in Middlesex County, Massachusetts; Dominion Cove Point LNG, LP 

(Cove Point) in Calvert County, Maryland; Southern LNG Inc. (Southern) in Chatham County, Georgia; 

and Trunkline LNG Company, LLC (Trunkline) at Lake Charles in Calcasieu Parish, Louisiana. 

Neither the Distrigas nor Cove Point terminals are viable alternatives to the Casotte Landing 

Project. Their location in the New England and Mid-Atlantic regions, respectively, in combination with 

the existing interstate pipeline infrastructure would not provide reasonable access to southeastern markets, 

which are the primary target market of the proposed Project. Thus, any additional LNG delivered to these 

terminals would serve their respective regional markets and would not meet the primary objective of the 

proposed Project. 

The Southern terminal, which is located on Elba Island in the Savannah River, approximately 

5 miles downstream of Savannah, Georgia, recently completed an expansion project that included the 

addition of a second and third docking berth, a fourth storage tank, and associated support facilities. The 

expansion project, which was approved by the FERC in April 2003, nearly doubled the terminal’s 

maximum sendout capacity to 1.2 Bcfd. Southern has also announced plans for an additional expansion 

project that would add additional storage, modify the docking facilities to accommodate larger LNG 

carriers, and nearly double the terminal’s sendout capacity. Further, two proposed and/or planned 

pipeline projects (Cypress and Elba Express) would increase the takeaway capacity at the terminal and 

enhance the Southern terminal’s connectivity to the interstate pipeline system. Due to its location, as well 

as existing and planned access to the interstate pipeline system, the Southern terminal would serve the 

same markets targeted by the proposed Project. However, all of the existing terminal capacity, including 

that associated with the recently completed expansion, is fully subscribed under long-term agreements. 

The Trunkline terminal, which is located in Lake Charles, Louisiana, is the largest operating LNG 

import terminal in the United States. This terminal has also recently received the FERC authorization for 

several expansion projects. The most recent such approvals authorized the addition of a fourth storage 

tank and a second marine unloading dock, as well as the addition of pumps and vaporizers that would 

increase the sustained daily sendout capacity of the terminal to 1.2 Bcfd. The Trunkline terminal provides 

access to multiple intra- and interstate pipelines. Given this factor and the terminal’s location along the 

Gulf of Mexico, the Trunkline terminal would potentially serve the same markets targeted by the 

proposed Project. 

3.3.1.2 Approved and Proposed Onshore LNG Terminals 

Over 25 onshore LNG terminals have recently been proposed for the United States. A number of 

these have been proposed along the West Coast or in the Mid-Atlantic and New England regions. As 

discussed previously, relative to existing LNG terminals, the existing interstate pipeline infrastructure in 

the Mid-Atlantic and New England regions would not provide reasonable access to the southeastern 

markets. Likewise, existing pipeline infrastructure along the West Coast is designed to provide local and 

regional distribution, such that an LNG terminal sited there would not have access to the markets targeted 

by the proposed Project. Because they would not satisfy one of the main objectives of the proposed 

Project, to access gas markets primarily in the southeastern United States, approved and proposed LNG 

import terminals located along the West Coast or in the Mid-Atlantic and New England regions are not 

considered to represent viable alternatives. 

As a historic source of domestic natural gas production, many interstate pipelines serving national 

markets, including those targeted by the proposed Project, originate along the central Gulf of Mexico. 

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Consequently, most of the recently approved and proposed onshore LNG import terminals would be 

located in this region. Table 3.3.1-1 identifies these facilities and summarizes the status of each terminal 

project. 

Authorized Projects 

As described in Table 3.3.1-1, the FERC has recently authorized the construction and operation 

of nine onshore LNG import terminals along the Gulf of Mexico. Currently, construction has commenced 

at five of those terminals. Construction is pending at the remaining four terminals. 

TABLE 3.3.1-1 

Approved and Proposed Onshore LNG Terminals Along the Gulf of Mexico 

Operator/Applicant 

Project 

Name 

FERC 

Docket 

Number Location 

Sendout 

Capacity 

(Bcfd) 

Total 

Storage 

Capacity 

(m3

) Statusa

Approved Terminals 

CP02-374 1.5 480,000 FERC approval 

issued September 

2003; construction 

underway. 

Cameron LNG LLC Cameron 

LNG 

Terminal 

Project 

PF06-10 

Hackberry, 

LA 

2.7 640,000 Expansion project 

pre-filing process 

request approved 

December 2005; 

environmental 

review in progress.

CP03-75 1.5 320,000 FERC approval 

issued June 2004; 

construction 

underway. 

Freeport LNG 

Development, LP 

Freeport LNG 

Project 

CP05-361 

Freeport, TX 

2.5 480,000 FERC issued 

environmental 

assessment for 

Phase 2 facilities 

in June 2006; 

NEPA 

environmental 

review in progress. 

CP04-47 2.6 FERC approval 

issued December 

2004; construction 

underway. 

Sabine Pass LNG, 

LP 

Sabine Pass 

LNG Project 

CP05-396 

Sabine 

Pass, LA 

4.0 

480,000 

FERC approval of 

Phase 2 facilities 

issued June 2006; 

construction 

underway. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-9

TABLE 3.3.1-1 (continued) 

Approved and Proposed Onshore LNG Terminals Along the Gulf of Mexico 

Operator/Applicant 

Project 

Name 

FERC 

Docket 

Number Location 

Sendout 

Capacity 

(Bcfd) 

Total 

Storage 

Capacity 

(m3) Statusa

Approved Terminals 

Corpus Christi LNG 

LP 

Cheniere 

Corpus 

Christi LNG 

Project 

CP04-37 Corpus 

Christi, TX 

2.6 480,000 FERC approval 

issued April 2005; 

construction 

underway. 

Vista Del Sol LNG 

Terminal LP 

Vista del Sol 

LNG 

Terminal 

Project 

CP04-395 Corpus 

Christi, TX 

1.4 465,000 FERC approval 

issued June 2005. 

Golden Pass LNG 

Terminal, LP 

Golden Pass 

LNG Project 

CP04-386 Sabine Pass, 

TX 

2.0 775,000 FERC approval 

issued July 2005; 

construction 

underway. 

Ingleside Energy 

Center LLC 

Ingleside 

Energy 

Center LNG 

Project 

CP05-13 Corpus 

Christi, TX 

1.0 320,000 FERC approval 

issued July 2005. 

Port Arthur LNG LP Port Arthur 

LNG Project 

CP05-83 Port Arthur, 

TX 

3.0 480,000 FERC approval 

issued June 2006 

Creole Trail LNG, LP Creole Trail 

LNG Project 

CP05-360 Cameron, LA 3.3 640,000 FERC approval 

issued June 2006. 

Proposed Terminals 

Calhoun LNG, LP Calhoun 

LNG Project 

CP05-91 Port Lavaca, 

TX 

1.0 320,000 FERC issued final 

EIS in November 

2006; NEPA 

environmental 

review in progress 

Gulf LNG Energy, 

LLC 

LNG Clean 

Energy 

Project 

CP06-12 Pascagoula, 

MS 

1.0 320,000 FERC issued final 

EIS in November 

2006; NEPA 

environmental 

review in progress 

Bayou Casotte 

Energy LLC 

Casotte 

Landing 

Project 

CP05-420 Pascagoula, 

MS 

1.3 480,000 FERC issued draft 

EIS in May 2006; 

NEPA 

environmental 

review in progress 

_________ 

NOTES: 

a Project status as of August 2006. More specific information for many of these projects can be obtained from the FERC 

document management system (http://www.ferc.gov/docs-filing/elibrary.asp). 

Bcfd billion cubic feet per day 

m3

 cubic meters 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-10

As proposed and approved, the Freeport terminal, which would be located on Quintana Island 

outside the City of Freeport, Texas, is only designed to serve the Texas intrastate market and would not 

provide access to the interstate pipeline system. Further, the proposed terminal capacity is already fully 

subscribed. The Freeport terminal would not satisfy the objectives of the Casotte Landing Project, and is 

therefore not considered a viable alternative to the proposed Project. Each of the remaining onshore LNG 

terminal projects would interconnect with the existing interstate pipeline systems, and would potentially 

serve the same markets targeted by the Casotte Landing Project. 

Proposed Projects 

In addition to the Casotte Landing Project, we have received and are currently reviewing 

applications for two other proposed onshore LNG terminals along the Gulf of Mexico, as described in 

Table 3.3.1-1. Though BP LNG had proposed construction of an additional onshore LNG terminal, the 

Bay Crossing terminal, which would be located on Pelican Island near Galveston, Texas, BP LNG 

recently announced that it is not currently proceeding with further work on that project. Further, we have 

not received a formal application for the Bay Crossing terminal. 

One of the formally proposed terminal projects would be sited a considerable distance from the 

proposed Project. The Calhoun terminal would be sited in Port Lavaca, Texas, about 500 miles from the 

proposed Project site. Even so, the Calhoun terminal project would interconnect with the existing 

interstate pipeline system. Therefore, this terminal project would potentially serve the same markets 

targeted by the Casotte Landing Project. 

In contrast, the proposed LNG Clean Energy Project would be sited along Bayou Casotte in 

Pascagoula, Mississippi, just south of the proposed Casotte Landing Project terminal site. The LNG 

Clean Energy Project would consist of ship berthing and unloading facilities capable of accommodating 

one LNG carrier, two 160,000 m3 storage tanks, 10 high pressure submerged combustion vaporizers, a 

5.0-mile-long, 36-inch-diameter sendout pipeline, and various support facilities. Gulf LNG Energy, LLC 

(Gulf LNG) anticipates that up to 150 LNG carriers would unload LNG at the proposed facility on an 

annual basis. The LNG Clean Energy Project would sendout up to 1.5 Bcfd of natural gas to national 

markets that can be accessed through interconnects with the Gulfstream and Destin pipeline systems, as 

well as an existing gas processing plant. Due to its proximity to the proposed Casotte Landing Project 

and its proposed interconnect with the interstate pipeline system, the LNG Clean Energy Project would 

potentially serve the same markets targeted by the Casotte Landing Project. 

3.3.1.3 Conclusions Regarding Onshore LNG Terminal System Alternatives 

As described above, the existing and proposed LNG import terminals along the West Coast or in 

the Mid-Atlantic and New England regions would not provide reasonable access to the markets targeted 

by the proposed Project. Likewise, the Freeport terminal would not interconnect with the interstate 

pipeline system. These terminal projects would therefore not meet the objectives of the proposed Project, 

and they have been eliminated from further consideration in our analysis. 

Two of the existing onshore LNG import terminals, the Southern and Trunkline terminals, and all 

but one of the approved and proposed onshore LNG import terminals along the Gulf of Mexico would 

provide access to the interstate pipeline system. With the exception of the LNG Clean Energy Project, 

each of the other terminal projects would be located more remotely from the southeastern markets that are 

the primary target of the proposed Project, which would be less attractive commercially and/or require 

development of additional pipeline infrastructure. Likewise, the capacity of many of these terminal 

projects has already been committed to customers through long-term agreements. Relative to the 

proposed Project, it is therefore unclear how efficiently or effectively, the other existing, approved, and 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-11

proposed LNG terminal projects would satisfy the objectives of the proposed Casotte Landing Project. 

Additionally, we are unsure whether those LNG terminal projects that have been proposed, but not yet 

constructed, will advance beyond the planning stages. Ultimately, the FERC does not consider these 

projects as true alternatives to one another. Rather we view each of the existing, approved, and proposed 

onshore LNG terminal projects to be potentially complementary for the purpose of meeting the United 

States’ projected energy demands. Each terminal project has been designed to satisfy a unique purpose 

and need (i.e., the projects are not readily interchangeable), and each has undergone, or would undergo, 

an independent environmental review process designed to ensure that potential environmental impacts 

resulting from their development are avoided, minimized, and/or mitigated. Although each LNG terminal 

would interconnect with existing interstate pipeline systems and would serve broader national markets, 

most would also target local and/or regional markets. As a result, it is likely that market forces, which 

include considerations for environmental impacts and associated permitting time and mitigation costs, 

will ensure that the LNG terminal projects that would ultimately be developed offer the optimal 

combination of environmental and financial benefits while being consistent with sustainable development 

in the regions for which they are proposed. 

Because the proposed Casotte Landing and LNG Clean Energy Project terminal sites are in close 

proximity to one another and both would interconnect with the existing Gulfstream and Destin pipeline 

systems, the FERC considered the alternative of combining them into a single LNG terminal system. In 

general, there are two avenues by which the goals of multiple LNG terminal projects would be satisfied 

by developing a single system alternative. First, a single company would build facilities that would 

satisfy the objectives of multiple terminal projects. However, the authorized and proposed LNG import 

terminals along the Gulf of Mexico, including the Casotte Landing and LNG Clean Energy Projects, 

are proposed by separate applicants and/or are designed to achieve unique objectives. Combining two or 

more of the projects into a single system would likely involve either the elimination of one or more of the 

proposals or a comprehensive synchronization of the respective LNG chains (source development to 

market). 

Second, two companies would build LNG facilities that would satisfy the objectives of their 

respective projects at a single property. However, in the case of the LNG Clean Energy Project, property 

at the proposed Casotte Landing Project terminal site is not available to Gulf LNG. Conversely, the 

Casotte Landing Project terminal site facilitates significant synergies with the Chevron Pascagoula 

Refinery (e.g., waste heat delivery and cool water return system, enhanced marine operability, and 

security and safety systems) that would be lost or reduced if sited at Gulf LNG’s proposed terminal site. 

Furthermore, we do not believe that there are significant advantages to combining or collocating two or 

more different LNG project facilities on a single property. If the LNG projects were built on a single site, 

additional space would be required to accommodate the construction of additional ship berths, storage 

tanks, vaporization equipment, and combined pipeline facilities, which would likely result in 

environmental impacts similar to that associated with the two individual projects. Further, construction of 

two LNG facilities at a single property would not lessen the effects to local ship traffic, and increased 

congestion in the immediate vicinity of a single marine terminal would pose significant logistical 

difficulties. 

In considering either of these approaches, we would first need to establish that unacceptable 

impacts exist at a proposed LNG terminal site. At this time, our environmental review of each terminal 

project has not revealed any unacceptable impacts. The FERC will evaluate each project individually 

based on its merits, and at the time of its decision will be fully apprised of the individual as well as the 

cumulative environmental impacts. To ensure that our analysis was complete and included local and 

regional issues, we conferred with appropriate agencies and held public scoping meetings. Section 4.13 

addresses the potential combined environmental impacts of construction and operation of multiple 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-12

LNG import terminal projects in the Pascagoula area, should both the Casotte Landing and LNG Clean 

Energy Projects proceed forward. 

3.3.2 Offshore LNG Terminal System Alternatives 

To avoid many of the environmental issues and safety concerns associated with locating an LNG 

terminal onshore, many companies have considered locating LNG import terminal facilities in offshore 

areas. As defined in the Deepwater Port Act of 1974 (as amended by the Maritime Transportation 

Security Act of 2002 to include natural gas facilities), deepwater ports include a fixed or floating structure 

(other than a vessel) or a group of structures that are located off the coast of the U.S. and that are used as 

a port or terminal for the transportation, storage, and further handling of oil or natural gas. This 

legislation requires that the DOT (U.S. Maritime Administration [MARAD]) and the Coast Guard 

regulate the licensing, siting, construction, and operation of deepwater ports for natural gas. Like onshore 

LNG terminals, offshore LNG terminal facilities located in state waters fall under the jurisdiction of the 

FERC. 

There is currently only one existing offshore LNG terminal in operation in the United States. 

However, more than a dozen offshore LNG terminals that would be located in Unites States waters have 

been formally proposed or are in the planning stages. The four main offshore technologies currently 

under development include: 

• shuttle regasification vessels (SRV); 

• gravity-based structures (GBS); 

• reuse of existing offshore platforms; and 

• floating regasification units (FRU). 

Many of the proposed offshore LNG terminal facilities would be located along the West Coast or 

in the New England region. As with the onshore LNG terminal system alternatives, offshore LNG 

terminals located in those regions would not satisfy one of the main objectives of the proposed Project, to 

access gas markets primarily in the southeastern United States. Therefore, our analysis of approved and 

proposed offshore LNG terminals was constrained to those facilities that would be located in United 

States waters along the Gulf of Mexico or South Atlantic coasts. Table 3.3.2-1 identifies these facilities 

and summarizes the status of each project. 

3.3.2.1 Shuttle Regasification Vessel 

An SRV is a specially designed LNG carrier that uses onboard vaporization equipment similar to 

that used at onshore LNG terminals to transfer regasified LNG to subsea pipelines via a floating buoy and 

riser system. The floating buoy is permanently attached to the seafloor using a 6- or 8-point mooring 

system, and a flexible pipeline riser is used to transfer regasified LNG received from the SRV into a 

subsea pipeline. 

The Gulf Gateway Energy Bridge (Gulf Gateway) terminal, owned by Excelerate Energy LP, 

uses SRV technology and is currently the only operational offshore LNG import terminal in the United 

States. The facility is located in the Gulf of Mexico, approximately 116 miles off the Louisiana coast. 

The Gulf Gateway terminal consists of a submerged turret loading buoy and associated flexible riser pipe 

and subsea manifold, a gas metering platform, and about 7 miles of subsea pipeline that provides 

interconnects with two offshore pipeline systems. The Gulf Gateway terminal has a sendout capacity of 

approximately 0.5 Bcfd during the 6 to 10 day period required for a berthed SRV to offload its cargo at 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-13

the terminal. Although as planned the Excelerate shipping fleet would include up to four SRVs, the Gulf 

Gateway terminal is currently only served by one SRV. 

TABLE 3.3.2-1 

Approved and Proposed Offshore LNG Terminals Located along the 

Gulf of Mexico or South Atlantic Coasts 

Operator/Applica

nt Project Name 

Coast 

Guard 

Docket 

Number Location 

Sendout 

Capacity 

(Bcfd) 

Total 

Storage 

Capacity 

(m3

) Statusa

Existing Terminals 

Excelerate Energy 

LP 

Gulf Gateway 

Energy Bridge 

14294/ 

21111 

Gulf of 

Mexico, 

offshore LA 

0.5 None Began operation in 

April 2005. 

Approved Terminals 

ChevronTexaco – 

Port Pelican LLC 

Port Pelican 

Offshore 

Deepwater 

Port Project 

14134 Gulf of 

Mexico, 

offshore LA 

2.0 330,000 Coast Guard and 

MARAD approvals 

issued November 

2003; project placed 

on hold indefinitely by 

applicant. 

Shell US Oil and 

Gas – Gulf 

Landing LLC 

Gulf Landing 

Project 

16877 Gulf of 

Mexico, 

offshore LA 

1.0 200,000 Coast Guard and 

MARAD approvals 

issued February 2005; 

awaiting decision on 

litigation filed 

challenging issuance 

of license. 

Proposed Terminals 

Freeport - 

McMoRan Energy, 

LLC 

Main Pass 

Energy Hub 

17696 Gulf of 

Mexico, 

offshore LA 

2.5 300,000 Coast Guard issued 

final EIS in March 

2006; project vetoed 

by Governor of 

Louisiana in May 

2006; amended 

application filed late 

May 2006; 

environmental review 

in progress. 

ConocoPhillips – 

Compass Port LLC 

Compass Port 

Project 

17659 Gulf of 

Mexico, 

offshore AL 

1.0 300,000 Application filed 

March 2004; Coast 

Guard issued final EIS 

in April 2006; 

application withdrawn 

in June 2006. 

ConocoPhillips – 

Beacon Port LLC 

Beacon Port 

Project 

21232 Gulf of 

Mexico, 

offshore LA 

1.5 300,000 Application filed 

January 2005; Coast 

Guard issued draft 

EIS in March 2006; 

environmental review 

in progress. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-14

TABLE 3.3.2-1 (continued) 

Approved and Proposed Offshore LNG Terminals Located along the 

Gulf of Mexico or South Atlantic Coasts 

Operator/Applicant 

Project 

Name 

Coast 

Guard 

Docket 

Number Location 

Sendout 

Capacity 

(Bcfd) 

Total 

Storage 

Capacity 

(m3) Statusa

TORP Terminal LP Bienville 

Offshore 

Energy 

Terminal 

N/A Gulf of 

Mexico, 

offshore AL 

1.4 None Application filed 

January 2006 and 

deemed complete in 

May 2006; 

environmental review 

in progress 

Proposed Terminals 

SUEZ Energy North 

America, Inc. 

Calypso 

LNG 

Deepwater 

Port Project 

N/A South 

Atlantic, 

offshore FL 

1.0 None Application filed 

March 2006, but 

deemed incomplete; 

revised application 

anticipated in late 

2006. 

_________ 

NOTES: 

a Project status as of August 2006. More specific information for many of these projects can be obtained from the Coast 

Guard document management system (http://dms.dot.gov/). 

Bcfd billion cubic feet per day 

m3 cubic meters 

N/A not applicable

SUEZ Energy North America, Inc. (SUEZ) recently filed an application with the Coast Guard for 

its proposed Calypso LNG Deepwater Port Project (Calypso), which would also make use of SRV 

technology. As proposed, the Calypso terminal would consist of two submerged turret loading buoys, 

which would allow at least one SRV to be moored at all times, yielding the flexibility to provide for 

continuous sendout of natural gas from the terminal. The Calypso Project would be located 

approximately 10 miles offshore of Port Everglades in south Florida, and would provide a sendout 

capacity of about 1.0 Bcfd through an interconnect with the planned Calypso U.S. Pipeline Project, which 

was previously evaluated by the FERC under Docket No. CP01-409-000. 

Though the Gulf Gateway and Calypso terminals would satisfy an objective of the proposed 

Project by providing natural gas service to southeastern markets through interconnects with existing 

interstate pipeline infrastructure, neither facility would provide any storage component. To ensure a 

continuous supply of gas, an SRV-based terminal would need to provide multiple unloading buoys 

serviced by a fleet of purpose-built SRVs or retrofit LNG carriers. Even though the Calypso terminal 

would provide multiple unloading buoys, the sendout capacity of that project would not achieve that of 

the proposed Project. Additionally, the location of the Calypso terminal was selected to meet the specific 

natural gas demands of the south Florida market, and substantial upgrades of the existing interstate 

pipeline infrastructure would be required to backhaul natural gas to the broader southeastern markets 

targeted by the proposed Project. For these reasons, we do not consider the Gulf Gateway terminal, the 

Calypso terminal, or SRV technology in general, to represent a viable alternative to the proposed Casotte 

Landing Project.

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-15

3.3.2.2 Gravity Based Structures 

A GBS offshore LNG terminal would consist of LNG storage tanks, offloading, and vaporization 

facilities placed on large concrete structures attached directly to the seafloor. LNG carriers would moor 

at the terminal and offload LNG, similar to an onshore LNG terminal. The LNG would then be regasified 

and sent out through interconnects with existing interstate pipeline systems using vaporizers and pumps 

housed at the terminal. Because the GBS must extend above the water surface but still enable access by 

deep-draft LNG carriers, GBS terminals are constrained to relatively shallow waters with a depth range of 

approximately 45 to 100 feet. The GBS itself would be constructed at a graving dock, which is a 

specialized onshore construction facility with adjacent channel depths sufficient to float the completed 

structure. Graving dock land requirements and associated environmental impacts would vary from site to 

site, but would typically range from 50 to 100 acres in size and require the dredging of between 2 and 

3 mcy of material. 

As described in Table 3.3.1-1, several offshore LNG terminals that incorporate GBS technology 

in their design has been proposed along the Gulf of Mexico. Both the Port Pelican and Gulf Landing 

terminals have received preliminary authorizations from the Coast Guard, and the Beacon Port terminal is 

currently under review. As proposed, these LNG terminal projects would provide storage capacities 

ranging from 200,000 m3

 to 300,000 m3, with sendout capacities of 1 to 2 Bcfd, both of which are similar 

to that of the proposed Casotte Landing Project. The locations of these terminals in the Gulf of Mexico 

would also satisfy another objective of the proposed Project, providing natural gas service to southeastern 

markets through interconnects with the existing interstate pipeline infrastructure. 

3.3.2.3 Reuse of Existing Offshore Platforms 

Abandoned platforms and associated infrastructure that exist in the Gulf of Mexico would also be 

converted for reuse as LNG import, storage, and vaporization terminals. Reuse of an existing platform 

would first require decommissioning of the existing production facilities. The platform would then be 

outfitted with LNG carrier berthing, LNG storage, and vaporization facilities, but depending on the 

specific design, reuse of an offshore platform may not include significant offshore storage facilities. Like 

with a GBS, LNG would be regasified and sent out through subsea pipelines to interconnects with 

existing interstate pipeline systems. Currently, there is one such project proposed in the Gulf of Mexico. 

The Main Pass Energy Hub (Main Pass) terminal would utilize an existing offshore platform to 

provide LNG carrier berthing, unloading, and vaporization facilities. The project would provide an LNG 

surface storage capacity of approximately 145,000 m3

, but would also make use of a nearby salt dome to 

provide underground storage of up to 28 bcf of natural gas. As proposed, the Main Pass terminal would 

provide sendout capacities of up to 3.1 Bcfd, and construction of approximately 192 miles of offshore 

pipeline and 5 miles of onshore pipeline would interconnect the project with the existing interstate 

pipeline infrastructure. As such, the Main Pass terminal would satisfy several objectives of the proposed 

Casotte Landing Project. 

3.3.2.4 Floating Regasification Units 

An FRU represents a new technological approach to providing LNG import terminal services. 

Under this approach, LNG offloading and vaporization equipment is housed on a floating, L-shaped 

structure equipped with positioning thrusters. LNG carriers of any design arriving at the terminal are 

moored using a single anchor leg mooring buoy. The FRU then docks onto the LNG carrier using a 

suction cup-like attachment system, and offloads, vaporizes, and sends out the vessel’s cargo via a 

flexible riser connected to a subsea pipeline, similar to the SRV technological approach. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-16

TORP Terminal LP filed an application with the Coast Guard for its proposed Bienville Offshore 

Energy (Bienville) project, which would be the first offshore LNG terminal to use FRU technology. As 

proposed, the Bienville terminal would consist of two FRUs and mooring buoys, as well as a support 

platform housing a control room, metering, and support facilities. Provision of two FRUs operating in 

tandem would allow at least one LNG carrier to be moored at all times, yielding the flexibility to provide 

for continuous sendout of natural gas from the terminal. The Bienville terminal would be located 

approximately 63 miles off of Dauphin Island, Alabama, less than 80 miles from the proposed Project, 

and each FRU would provide a sendout capacity of up to 1.4 Bcfd through interconnects with existing 

interstate pipeline infrastructure. 

The Bienville terminal would satisfy an objective of the proposed Casotte Landing Project by 

providing natural gas service to southeastern markets, and unlike the Gulf Gateway terminal, the tandem 

design of the project would facilitate continuous sendout of natural gas at a capacity similar to that of the 

proposed Project. Further, the design of the floating regasification unit would not result in the need for a 

fleet of specialized LNG carriers. However, the Bienville terminal would not provide for storage of LNG, 

which is one of the primary objectives of the proposed Project. For this reason, we do not consider the 

Bienville terminal, or FRU technology in general, to represent a viable alternative to the proposed Casotte 

Landing Project. 

The floating, storage and regasification unit (FSRU) represents a similar approach to FRU 

technology that is being considered by some companies to provide for LNG imports into the United 

States. Unlike an FRU, an FSRU would provide for onboard storage of LNG in addition to offloading 

and vaporization facilities. An FSRU would resemble an oversized LNG carrier and provide storage 

capacities between 250,000 and 350,000 m3

 of LNG, over twice the capacity of most typical LNG 

carriers. An FSRU would be permanently moored to an offshore platform or floating buoy, and LNG 

carriers would berth alongside it to accomplish offloading of their LNG cargoes. After offloading, LNG 

stored in the FSRU would be vaporized and sent out at capacities up to about 1 Bcfd through subsea 

pipelines and interconnects with existing interstate pipeline infrastructure. Though several companies 

have proposed the use of FSRU technology off the West Coast and in the Long Island Sound area, no 

projects of this type have yet been proposed for the Gulf of Mexico. 

3.3.2.5 Conclusions Regarding Offshore LNG Terminal System Alternatives 

We have considered existing, approved, and proposed offshore LNG terminals and technologies 

to determine if they would meet the proposed Project objectives while avoiding or reducing impacts to 

environmentally sensitive resources. Though an offshore LNG terminal would avoid or minimize some 

of the environmental impacts associated with the proposed Project (e.g., permanent fill of coastal 

wetlands, dredging and dredge material placement impacts, public safety concerns raised by local 

residents), there are operational and environmental tradeoffs associated with offshore LNG terminal 

technology. 

Though an offshore LNG terminal might reduce some onshore public safety concerns, it would 

not entirely eliminate concerns for potential conflicts with recreational or commercial navigation. 

Though the siting process for an offshore LNG terminal includes considerations for locating a terminal in 

areas removed from shipping fairways and operational oil or gas platforms, a permanent, safety zone 

would be established at an offshore LNG terminal. The safety zone would entirely preclude commercial 

or recreational navigation and fishing within a 1,640-foot (500-m) radius around the terminal. 

Additionally, any anchoring of vessels would be precluded in an area up to 1 nautical mile in diameter 

around an offshore terminal. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-17

Relative to an onshore terminal, an offshore LNG terminal would be more exposed to metocean 

(weather and marine related) conditions. Unsuitable metocean conditions would result in significant 

periods when LNG carriers would be unable to unload their cargo due to excessive relative motion 

between the LNG carrier and the offshore terminal berth, reducing the long-term reliability of such a 

facility. This factor would be particularly exacerbated for those offshore terminal technologies that do not 

provide LNG storage capabilities (i.e., SRV and FRU). For facilities employing those technologies, any 

disruption of the shipping supply chain would result in an inability to deliver a reliable supply. 

With the exception of the amended application filed for the Main Pass terminal, each of the 

offshore LNG terminal facilities proposed to date in the Gulf of Mexico would use seawater as the 

primary heat source for vaporization of LNG. As described in Section 3.5.2, this requires the intake and 

discharge of large volumes of seawater, which could adversely affect marine life by entraining 

ichthyoplankton and lead to localized water quality concerns. For these reasons, NOAA Fisheries and 

various non-governmental organizations have opposed the use of seawater warmed vaporization 

technology at other LNG projects in the Gulf of Mexico. 

Use of an offshore facility would not preclude potential impacts too onshore or nearshore 

facilities and resources. As described previously, a GBS must be constructed at a graving dock, which 

can range in size from 50 to 100 acres and require the dredging of material volumes similar to that of the 

proposed Project. Permanent onshore facilities would also be required to support an offshore terminal. 

Likewise, an offshore LNG terminal would likely require a longer sendout pipeline to provide an 

interconnect with existing pipeline infrastructure. Construction of a longer pipeline would result in 

additional environmental concerns, especially if a pipeline crossing of sensitive coastal resources (e.g., 

submerged aquatic vegetation beds, coastal marsh, Gulf sturgeon critical habitat, etc.) were required. 

In addition to the operational and environmental tradeoffs described above, economic feasibility 

must also be considered. Some estimates have placed the capital cost for constructing an offshore 

terminal that includes significant LNG storage component at approximately twice that of a comparable 

onshore terminal. We note that ExxonMobil withdrew its application with the Coast Guard for the Pearl 

Crossing Project, a deepwater port LNG terminal that was proposed for construction off the coast of 

Louisiana. Similarly, ConocoPhillips withdrew its application for the Compass Port Project in June 2006. 

Additionally, though the Port Pelican terminal received approval from the Coast Guard, ChevronTexaco 

Corporation, and the parent company of Port Pelican, LLC, announced in July 2005 that it has placed that 

project on hold indefinitely. These factors do not provide reasonable assurances that an offshore LNG 

terminal would represent an economically viable or practicable alternative to the proposed Project. 

In summary, many of the existing, approved, and proposed offshore LNG terminals and 

technologies evaluated in our analysis would satisfy some objectives of the proposed Casotte Landing 

Project, as described above. Though we acknowledge that the existing, approved, and proposed offshore 

LNG terminal projects and technologies would provide an alternative means for the import of LNG, we 

do not consider that any of them would provide the capabilities of the proposed Project. Further, we do 

not consider that any of the offshore LNG terminal technologies represent an environmentally preferable 

or technically and economically feasible and practical alternative to the proposed Project. Additionally, 

we are unsure whether those offshore LNG terminal projects that have been proposed, but not yet 

constructed, will advance beyond the planning stages. As with our analysis of existing, approved, and 

proposed onshore LNG terminals (see Section 3.3.1.3), the FERC does not ultimately view any of the 

existing, approved, or proposed offshore LNG terminal projects as true alternatives to the proposed 

Project. Rather we view each of the existing, approved, and proposed offshore LNG terminal projects to 

be potentially complementary for the purpose of meeting the United States’ projected energy demands. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-18

3.3.3 Pipeline System Alternatives 

As an alternative to constructing a new LNG import terminal, we considered the feasibility of 

utilizing or expanding existing pipeline systems to provide an equivalent amount of natural gas to the 

markets that would be served by the proposed Casotte Landing Project. Expansion of existing pipeline 

systems alone would not supply these markets with new, non-domestic sources of natural gas, as the 

proposed Project would. As described in Section 1.1, demand for natural gas is outpacing domestic 

supplies. Pipeline system alternatives would therefore be unable to meet the objectives of the proposed 

Project and were not considered further in our analysis. 

3.4 LNG TERMINAL SITE ALTERNATIVES 

In evaluating a potential location for the proposed Casotte Landing Project, Bayou Casotte 

Energy considered its specific objectives for the proposed Project, with primary focus given to the 

following factors: 

• proximity to existing natural gas and NGL infrastructure and associated markets; 

• marine operability and port capabilities to accommodate LNG carriers from approximately 

125,000 m3 to 200,000 m3 capacity; 

• ability to provide synergies with other existing Chevron owned businesses; and 

• minimization of environmental impact from construction and operation. 

A location in proximity to the Chevron owned and operated Pascagoula Refinery on Bayou 

Casotte in Pascagoula, Mississippi, would satisfy all of these factors. A primary objective of the 

proposed Project is to provide direct access to southeastern natural gas markets, as well as broader United 

States markets, through interconnects with the existing pipeline infrastructure. Existing pipeline 

infrastructure in the immediate vicinity of the Refinery provides over 4.0 Bcfd of takeaway capacity that 

provides direct and indirect access (through interconnects with other pipeline systems) to markets in the 

southeastern United States, as well as the Mid-Atlantic and New England regions. NGL pipeline 

infrastructure in the vicinity of the Refinery is also well developed. Additionally, a site along Bayou 

Casotte provides ready access to an existing deepwater shipping channel. Bayou Casotte Energy also 

reports that a site in proximity to the Refinery would provide numerous synergies and benefits including 

use of existing Refinery services for security and safety, access to lands owned and controlled by Chevron 

to minimize impacts to other property owners, and use of waste heat from the Chevron Pascagoula 

Refinery to accomplish LNG vaporization. As described in Section 3.5.2.3, utilization of heated utility 

water from the Refinery’s cooling towers as a heat source for LNG vaporization would provide numerous 

environmental benefits over other alternative vaporization technologies. 

For these reasons, we consider that other potential locations would be unlikely to satisfy the 

proposed Project objectives, and we did not conduct a detailed regional screening analysis to identify 

alternative terminal locations. Additionally, we note that the regional screening analysis performed for 

the LNG Clean Energy Project, which did not include an objective for providing synergies with other 

existing Chevron owned businesses, resulted in convergent selection of a proposed terminal site in 

Pascagoula, Mississippi. 

3.4.1 Local Siting Alternatives 

Based on the above analysis, proximity to the Chevron Pascagoula Refinery was identified as a 

critical component in siting an LNG terminal that would meet the specific project objectives of Bayou 

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Casotte Energy. We therefore considered other local siting alternatives in the vicinity of the Refinery to 

determine whether other alternative sites would meet the proposed Project objectives while avoiding or 

reducing impacts to environmentally sensitive resources and representing a technically and economically 

feasible and practical solution. The proposed LNG terminal site and associated facilities are described in 

Section 2.1.1. Two alternative terminal sites, the South and Point aux Chenes Site Alternatives, were 

evaluated in our analysis. These alternative terminal sites are depicted in Figure 3.4.1-1, and the various 

criteria used in our analysis are provided in Table 3.4.1-1. 

TABLE 3.4.1-1 

Comparison of Local Siting Alternatives for the Proposed Casotte Landing Project 

Comparative Category Unit Proposed Site South Alternative 

Point aux Chenes 

Alternative 

LNG carrier berth design N/A Off-channel slip Jetty Jetty 

Primary land use N/A Former industrial site BCDMMS BCDMMS 

Excavation/dredged 

material volume mcy 4.5 1.8 12.0 

Total wetlands affecteda Acres 118 136 187 

Estuarine emergent Acres 54 129 167 

Palustrine emergent Acres 59 0 0 

Palustrine scrub shrub Acres 5 0 0 

Palustrine forested Acres 0 7 17 

Waterbodies affecteda,b Number 2 2 3b

Essential Fish Habitat 

affectedc Acres 21 41 71 

_________ 

a All wetland and waterbody impacts estimated from National Wetlands Inventory data, and therefore reported values for the 

proposed terminal site may differ from actual numbers provided elsewhere in this document. 

b All potentially affected waterbodies consist of man-made canals or ponds, except for the South Site Alternative, which would 

affect one tidal creek. 

c All affected open water areas were assumed to represent Essential Fish Habitat. 

N/A Not applicable 

BCDMMS Bayou Casotte Dredged Material Management Site 

mcy million cubic yards 

The berthing facility design contemplated by Bayou Casotte Energy at both the South and Point 

aux Chenes Site Alternatives would consist of a berth located at the end of a new jetty and would not 

provide for creation of an off-channel slip, as would the proposed terminal site. As such the dredge 

material volume associated with the South Site Alternative would represent that material removed to 

expand the existing Bayou Casotte turning basin and access the existing channel. The dredge material 

volumes associated with the Point aux Chenes Site Alternative would represent that required to provide a 

dedicated channel east of the existing Bayou Casotte channel, as well as a new turning basin. In the case 

of the South Site Alternative, adoption of a jetty berthing facility design would reduce the amount of 

material that would need to be excavated, dredged, and/or disposed of relative to the proposed terminal 

site. However, berthing of LNG carriers in an off-channel slip would be optimal from a safety and 

security perspective, as it would reduce potential conflicts with existing commercial and recreational 

marine traffic and minimize the chances of allision by passing vessels. 

As described in Table 3.4.1-1, adoption of either the South or Point aux Chenes Site Alternatives 

would not reduce potential Project impacts to wetlands, waterbodies, or EFH. Additionally, Bayou 

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FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Page 3-20 

Figure 3.4.1-1 Proposed Casotte Landing Project 

Local Siting Alternatives 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Casotte Energy has identified several technical concerns with both site alternatives. The berthing 

design of both alternatives would also increase the separation between the LNG carrier berth and the LNG 

storage tanks relative to the proposed terminal site design, and would result in cryogenic transfer lines 

5,000 to 7,000 feet longer than that proposed, which represents a technical and economic constraint. 

While the proposed terminal site would occupy a former industrial site, the South and Point aux Chenes 

Site Alternatives would conflict with the Bayou Casotte Dredged Material Management Site (BCDMMS), 

which is an active dredged material placement area. Reduction in size of either the South or Point aux 

Chenes sites to avoid conflict with the BCDMMS would require that LNG storage tanks and associated 

facilities be located remote from the LNG carrier berthing. As the most likely candidate site for siting of 

the LNG storage tanks would be at the proposed terminal site, adoption of either the South or Point aux 

Chenes Site Alternatives might not preclude use of the proposed terminal site. For these reasons, we 

eliminated both of the local terminal siting alternatives from further consideration. 

3.5 LNG TERMINAL DESIGN ALTERNATIVES 

3.5.1 Terminal Slip Configuration Alternatives 

The proposed Project would include the construction of a vessel berthing and unloading slip off 

of the Bayou Casotte shipping channel. The proposed slip design would require the excavation, dredging, 

and removal of approximately 4.5 mcy of material, approximately 3.5 mcy of which would be disposed of 

at the Pascagoula ODMDS, as proposed. We evaluated alternative slip configurations to determine 

whether they would reduce the required volumes of dredged material while still being technically feasible 

and practical. 

Consistent with the proposed Project objectives, the proposed terminal slip would accommodate 

LNG carriers up to 200,000 m3

 capacity by providing a dredged elevation of 46 feet below MLLW. This 

dredge elevation would encompass a 42 foot design depth, 2 feet of advanced maintenance dredging, and 

an additional 2 feet of over depth dredging allowance. Each of the alternative slip configurations 

evaluated would provide the same dredge design depth. As described in Section 3.4.1, berthing of LNG 

carriers in an off-channel slip would be optimal from a safety and security perspective. Construction of a 

parallel berth alongside the existing Bayou Casotte channel was therefore not evaluated in detail. The 

following terminal slip configuration alternatives were evaluated in our analysis: 

• Option 1 - Angled Slip with LNG and Crude Berths (the proposed action); 

• Option 2 - Long Slip with LNG and Crude Berths; 

• Option 3 - Short Slip with LNG and Crude Berths; and 

• Option 4 - Angled Slip with LNG Berth Only. 

The alternative terminal slip configurations evaluated are depicted in Figure 3.5.1-1, and the 

various criteria used in our analysis are provided in Table 3.5.1-1. 

As described in Section 2.2, construction of an off-channel slip at the proposed terminal site 

would require relocation of the Refinery’s existing Berth 7, which is used to receive deliveries of crude 

oil and export refined products. Bayou Casotte Energy’s proposed action, Option 1, would accommodate 

relocation of Berth 7. The angled design of the slip would also enhance marine maneuverability and 

navigation and avoid the need for expansion of the existing Bayou Casotte turning basin, which Bayou 

Casotte Energy has estimated would require dredging and disposal of an additional 1.4 mcy of dredge 

material. Further the width of the proposed terminal slip would provide sufficient room for operation of 

LNG carriers, crude tankers, and tugs. 

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FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Page 3-22 

Figure 3.5.1-1 Proposed Casotte Landing Project 

Terminal Slip Configuration Alternatives 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 3.5.1-1 

Terminal Slip Configuration Alternatives for the Proposed Casotte Landing Project. 

Slip Configuration 

Alternative 

Dredged material 

volume 

(mcy) 

Achieves marine 

synergiesa

 Marine operability considerations 

Option 1 4.5 Yes Marine navigation enhanced by the approximate 

30° slip angle and slip width. 

Option 2 9.1b Yes LNG carrier berth further removed from channel, 

enhancing safety and security considerations. 

Relative to Option 1, marine navigation more 

difficult due to the higher degree of complexity and 

tighter turns in and out of the narrower slip. 

Option 3 4.6b Yes Relative to Option 1, marine navigation more 

difficult due to the higher degree of complexity and 

tighter turns in and out of the narrower slip. 

Option 4 4.0 No Marine navigation enhanced by the approximate 

30° slip angle, but the narrower channel lane and 

slip entrance would result in higher degree of 

complexity relative to Option 1. 

____________ 

Notes: 

a This metric evaluates whether the alternative would accommodate relocation of Chevron Pascagoula Refinery Berth 7. 

b

 An additional 1.4 mcy of material would be dredged in association with these alternatives to expand the existing Bayou Casotte

turning basin. 

As described in Table 3.5.1-1, both Options 2 and 3 would both accommodate relocation of 

Berth 7. However, both of these alternatives would require dredging of greater volumes of material than 

Option 1, including additional dredging of the Bayou Casotte turning basin. Relative to Option 1, the 

approximate 90° orientation of the slip to the existing Bayou Casotte channel under Options 2 and 3 

would also complicate marine navigation for vessels entering and departing the slip. For these reasons, 

Options 2 and 3 were eliminated from further consideration. 

Option 4 would result in the smallest amount of dredge material volumes of any alternative 

evaluated, and the angled slip design of Option 4 would provide marine navigation benefits for LNG 

carriers similar to that of Option 1. However, the narrower slip channel and entrance would result in a 

higher degree of marine maneuverability complexity than Option 1. Further, Option 4 would not 

accommodate relocation of the Refinery’s existing Berth 7. Failure to relocate Berth 7 would interfere 

with the Refinery’s existing operations and would not achieve one of Bayou Casotte Energy’s Project 

objectives, to provide synergies with other existing Chevron owned businesses. For this reason, Option 4 

was eliminated from further consideration. 

In summary, we do not consider any of the alternative slip configurations evaluated to represent a 

technically or environmentally preferable alternative to Bayou Casotte Energy’s proposed terminal slip 

design. 

3.5.2 Vaporization Technology Alternatives 

As described in Section 2.1.1.4, LNG must be warmed from a liquid to a gaseous state 

(vaporized) before it can be transported as natural gas in the sendout pipeline. This section describes the 

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vaporization technology alternatives considered for the Casotte Landing Project and the associated 

environmental impacts. The following vaporization technologies were evaluated: 

• submerged combustion vaporization (SCV); 

• shell and tube vaporization (STV) with gas fired heaters; 

• intermediate fluid vaporization (IFV); 

• open rack vaporization (ORV); and 

• ambient air heated vaporization. 

3.5.2.1 Submerged Combustion Vaporization 

SCV technology uses water heated by combustion exhaust to warm and vaporize LNG. An SCV 

system typically consists of a water bath containing stainless steel tubes (vaporization coils) and a 

submerged combustion chamber. LNG would be pumped through the vaporization coils submerged in 

the heated water bath, where it would be warmed and vaporized. The water bath would be cooled during 

this process as it transfers heat to the LNG. Cooled water would then be reheated in the submerged 

combustion chamber. The hot exhaust from the combustion chamber would be sparged into the water 

bath (i.e., the exhaust would be introduced into the liquid), thus transferring the heat necessary to vaporize 

the LNG. The combustion units would use vaporized LNG (natural gas) as a fuel source, and SCVs 

typically consume about 1.5 percent of the sendout natural gas from an LNG terminal. 

The primary byproducts from burning natural gas for the SCV process would be carbon dioxide 

(CO2) and water. Though water generated by the combustion process would be used as the water bath, 

excess combustion water would also result. CO2 absorbed into the water bath would create a low (acidic) 

pH, necessitating chemical treatment to neutralize excess combustion water prior to discharge. A SCV 

system capable of providing the sendout capacity proposed by Bayou Casotte Energy would likely result 

in a daily discharge of more than 200,000 gallons of treated wastewater. Furthermore, since SCVs rely on 

combustion of natural gas, this technology would also produce air emissions, including CO2, CO, and 

NOx. 

SCV is a widely used and proven technology, and it is generally considered to represent a viable 

and safe vaporization technology alternative. SCV technology is currently in use at the Southern terminal 

at Elba Island, Georgia, and the Trunkline terminal at Lake Charles, Louisiana, and has also been 

approved for use at the Cameron and Sabine terminals located near Hackberry and Sabine Pass, 

Louisiana, respectively. 

3.5.2.2 Shell and Tube Vaporization with Gas Fired Heaters 

STV technology uses a heat exchange medium, typically a glycol/water solution, that is circulated 

in a closed loop to warm and vaporize LNG, which is conveyed through the heat exchange medium in 

tubes. Though multiple heat sources can be used to warm the heat exchange medium, under the gas-fired 

approach, conventional gas-fired heaters are used, typically resulting in consumption of approximately 

1.6 percent of the sendout natural gas from an LNG terminal. Like SCVs, gas-fired STVs also produce 

air emissions, particularly NOx. However, since conventional gas-fired heaters are used, they can be 

constructed with effective emission control devices (e.g., selective catalytic reduction technology) that 

can’t be used with SCV systems. 

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Gas-fired STV is also a widely used and proven technology. It is currently in use at the Distrigas 

and Cove Point terminals, as well as the Guayanilla Bay terminal in Puerto Rico, and has also been 

approved for use at the Vista del Sol terminal in San Patricio County, Texas. 

3.5.2.3 Intermediate Fluid Vaporization 

IFV technology uses a glycol/water solution that is circulated in a closed loop as the heat medium 

to vaporize LNG via a shell and tube heat exchanger. Depending on the heat source used to warm the 

glycol mixture, several configurations of IFVs are possible. Gas-fired heaters may be used as a heat 

source, but the use of gas-fired heaters results in air emissions, as described above (see Section 3.5.2.2). 

Seawater may also be used as a heat source. Under this approach, heat transferred from the seawater to 

the glycol mixture through a series of plate and frame exchangers would then be transferred to the LNG 

via a shell and tube heat exchanger. However, this approach would share many of the disadvantages 

noted for an open-loop ORV system (see Section 3.5.2.4). Heated wastewater generated by industrial 

operations may also be used as a heat source to warm the glycol mixture. 

For the proposed Project, Bayou Casotte Energy has proposed the use of waste heat from the 

adjacent Chevron Pascagoula Refinery to accomplish vaporization, as described in Section 2.1.1.4. 

Specifically, heated wastewater from the Refinery’s cooling towers would be transferred to the LNG 

terminal site via a nonjurisdictional water circulation system using one set of pumps. A second set of 

pumps would circulate a 25 percent polypropylene glycol/water solution in a closed loop at the proposed 

terminal site. The glycol solution would transfer heat received from the heated wastewater to the LNG 

via a shell and tube heat exchanger, where vaporization would occur. Cooled water resulting from the 

transfer of heat to the glycol solution would subsequently be returned to the Refinery through the water 

circulation system, and would assist in meeting the cool water needs of that facility’s operations. 

Though the use and storage of propylene glycol represents a potential environmental impact in 

the event of an accidental release of the compound, propylene glycol is generally considered a relatively 

benign chemical. Further, mixture with water would improve the safety of the system as diluted 

propylene glycol has no measurable flash point. A similar system has been approved for use at the 

Ingleside terminal in San Patricio County, Texas. 

3.5.2.4 Open Rack Vaporization 

ORV typically utilizes seawater as the LNG warming medium. Under this approach, LNG is 

pumped through a series of aluminum heat transfer tubes arranged in a rack. Seawater is drawn in 

through screened water intakes and passed over the heat transfer rack to warm the LNG before being 

discharged back to the ocean in an open-loop. To prevent marine growth (biofouling) on the water 

intakes and inside the warming water system, sodium hypochlorite (bleach, an oxidizer) is typically added 

to the seawater in the system on a continuous basis. As it exchanges heat with the LNG, the seawater is 

cooled such that the discharge is typically 13 to 22 °F cooler than the ambient seawater (Exponent 2005). 

ORV is only effective as the sole source of vaporization when seawater temperatures exceed 63 °F. At 

seawater temperatures of 50 to 63 °F, supplemental methods of LNG warming are needed to maintain 

sendout capacity. Supplemental heating would typically be provided using gas-fired heaters similar to 

those used for SCV or STV systems. 

ORV technology is widely used for LNG vaporization at LNG terminals in warm water areas, 

including Japan, Korea and portions of Europe (Yang and Huang 2004), and it has been approved for use 

at the Port Pelican and Gulf Landing terminals in the Gulf of Mexico. However, open-loop ORV 

technology requires the use of large volumes of seawater. To provide the sendout capacity proposed by 

Bayou Casotte Energy would require the withdrawal and discharge of well over 100 million gallons of 

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seawater on a daily basis, which would affect marine life by killing ichthyoplankton unable to escape 

from the intake area. Further, the discharge of cooled and chemically treated seawater would also affect 

marine life and water quality, although the effects would be localized. For these reasons, NOAA 

Fisheries has opposed the use of open-loop ORV technology at other LNG projects in the Gulf of Mexico. 

Bayou Casotte Energy initially considered an ORV system that would make use of a closed-loop 

of heated wastewater from the Refinery as a heating medium rather than seawater. This closed-loop ORV 

alternative would avoid the withdrawal and discharge of large amounts of seawater, as well as the use of 

an intermediate, glycol/water heating medium. However, Bayou Casotte Energy indicated that copper 

concentrations in the Refinery wastewater stream would corrode the aluminum components of an ORV 

system, resulting in reduced system reliability and higher maintenance costs. 

3.5.2.5 Ambient Air Heated Vaporization 

Ambient air heated vaporizers, operating in either a natural or forced draft mode, use heat from 

surrounding air to warm and vaporize LNG. Ambient air temperature and the amount of supplemental 

heating available affect the size and performance of these units. If proposed as the sole means of 

vaporization, ambient air must be warm enough to vaporize LNG year round, and this approach is only 

suited for LNG terminals in very warm climates, such as the Petronet LNG terminal in Dahej, India 

(Yang and Huang 2004). As with ORV technology, LNG terminals in more temperate climates would 

require supplemental heat from SCVs or STVs during cooler weather. Additionally, condensation that 

results from the cooling of air associated with these systems can result in the production of significant 

amounts of freshwater, which must be disposed of. Further, water that is condensed on the heat exchange 

surfaces may freeze. Periodic downtime to facilitate melting of built-up ice greatly reduces the 

performance and efficiency of these systems. 

3.5.2.6 Vaporization Technology Alternatives Conclusions 

After reviewing the alternative vaporization technologies described above, none are considered 

environmentally preferable to Bayou Casotte Energy’s proposed approach, IFV technology using a heated 

wastewater stream as the heating medium. This conclusion was reached using the following rationale: 

• Though SCV and gas-fired STV represent widely used and proven technology, both 

technologies would result in air emissions, as well as consumption of sendout gas. 

• Open-loop ORV technology does not have regulatory agency support due to potential impacts 

on aquatic biota, and a closed-loop ORV system would reduce system reliability and increase 

maintenance costs. Both systems would also likely require supplemental or back-up 

vaporization capacity using SCV or gas-fired STV technology. 

• Ambient air-heated vaporization would require up to 100 percent supplemental vaporization 

capacity using SCV or gas-fired STV technology, which would offset the environmental 

advantages of this system. Further, the efficiency and performance of these systems is 

uncertain. 

• The proposed IFV system would use a readily available heat source, heated industrial 

wastewater, to avoid the potential impacts (e.g., air emissions, large water withdrawals and/or 

discharges, etc.) associated with other technologies. Additionally, this alternative would 

achieve synergies with other existing, Chevron owned businesses, thereby meeting one of 

Bayou Casotte Energy’s objectives. 

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Although gas-fired STVs were not selected as an environmentally preferred vaporization 

technology for the Casotte Landing Project, this technology is considered to represent a widely used and 

proven technology, with minimal environmental affects. To enhance the long-term reliability of the 

proposed Project, Bayou Casotte Energy has proposed the use of a similar system to provide a back-up or 

supplemental vaporization capacity, in the event the Refinery cooling water system is unavailable or 

inadequate (e.g., full or partial Refinery outage or periods of colder supply water). The back-up 

vaporization system proposed by Bayou Casotte Energy would provide enough heat to maintain a sendout 

rate of 0.9 Bcfd, by using two, gas-fired process heaters associated with the nonjurisdictional NGL plant 

to directly heat the glycol/water solution used in the closed-loop IFV system. 

The proposed back-up vaporization system would make use of existing facilities and systems, 

thereby eliminating the need for construction of an altogether separate back-up system. Additionally, the 

process heaters employed in the back-up vaporization system would be fitted with emission controls and 

would not significantly affect air quality, as described in Section 4.11.1. For these reasons, we did not 

consider alternatives to the proposed back-up vaporization technology in further detail. 

3.5.3 Electrical Power System Alternatives 

During operation, the proposed LNG terminal would require about 27 megawatts of electrical 

power. This power demand would be supplied in one of two ways, on-site generation through 

construction of a new, gas-fired electric generation facility or by purchase from an existing public utility. 

Bayou Casotte Energy considered on-site generation at the proposed LNG terminal, but 

determined that an on-site electric generation facility would increase site air emissions (primarily NOx) 

and require substantial capital costs. Bayou Casotte also considered obtaining power for the proposed 

Project from an existing Mississippi Power Company (MPC) substation located at the Refinery, but this 

alternative was eliminated due to a lack of sufficient, available power. Bayou Casotte Energy has 

proposed to provide electric power to the Casotte Landing Project terminal through construction of one 

main electrical substation and four smaller substations within the footprint of the LNG terminal site. 

Approximately 2 circuit miles of new, 115 kV transmission line constructed by MPC would link the 

substations to the existing electric transmission grid. 

The most probable route for the electric transmission line would parallel Highway 611, an 

existing industrial and transportation corridor. Further, permits required for the installation of the 

transmission line would minimize any potential environmental impacts associated with its construction. 

For these reasons, we do not consider on-site power generation to represent an environmentally preferable 

alternative and have eliminated it from further consideration. 

3.6 PIPELINE INTERCONNECT ALTERNATIVES 

3.6.1 Pipeline Route Alternatives 

We considered route alternatives for the proposed Gulfstream pipeline interconnect spur to 

determine if alternative pipeline alignments would avoid or reduce impacts to environmentally sensitive 

resources that would be crossed by the proposed pipeline. In conducting our analysis, we gave primary 

consideration to the use, enlargement, or extension of existing rights-of-way over developing a new rightof-way in order to reduce potential impacts on sensitive resources, consistent with the FERC regulations 

(18 CFR, Section 380.15[d][1]). In general, installation of new pipeline along existing, cleared rights-ofway (e.g., pipeline, powerline, road, or railroad) may be environmentally preferable to construction along 

new rights-of-way. Construction effects and cumulative impacts can normally be reduced by use of 

previously cleared rights-of-way. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-28

In addition to the alternatives identified below, it is anticipated that minor alignment shifts would 

be required prior to and during construction to accommodate currently unforeseeable site-specific 

constraints related to engineering, landowner, and environmental concerns. All such alignment shifts 

would first be subject to post-certificate review and approval by the FERC. 

As proposed, the Project pipeline facilities would consist of a 36-inch-diameter pipeline 

interconnect spur that would exit the terminal site traversing north along Ranson Road, then east to a 

terminus at an interconnect with the existing 36-inch-diameter Gulfstream pipeline (see Figure 2.1.3-1). 

Along its route and near the northeastern corner of the proposed LNG terminal site, the pipeline 

interconnect spur would pass adjacent to the existing 12-inch-diameter Gulf South, 36-inch-diameter 

Destin, 16-inch-diameter Chandeleur, and 12-inch-diameter Chandeleur pipelines, and short laterals 

would facilitate interconnections with those pipeline systems, as described in Section 2.1.3. Each of the 

latter pipeline interconnect laterals would be short (less than 0.1 mile in length) and constructed within 

existing pipeline rights-of-way adjacent to the proposed terminal site. Further, any modification of the 

proposed route for the 36-inch-diameter pipeline interconnect spur would not appreciably affect the 

location and route of the pipeline interconnect laterals. Consequently, only route alternatives for the 

36-inch-diameter pipeline interconnect spur were evaluated in our analysis. 

Three alternatives for the proposed 36-inch-diameter pipeline interconnect spur were evaluated. 

These alternatives are depicted in Figure 3.6.1-1, and Table 3.6.1-1 provides a detailed comparison of 

each route alternative with the proposed Project route. 

Route Alternative A would generally follow the proposed route, and would only differ from the 

proposed route in that it would tie-in to the existing Gulfstream pipeline slightly farther north than the 

proposed route. As indicated in Table 3.6.1-1, Route Alternative A would not provide any reduction in 

affected environmental resources, but would be longer than the proposed route and encumber more land 

within construction and permanent rights-of-way. For these reasons, Route Alternative A was eliminated 

from further consideration. 

Both Route Alternatives B and C would differ from the proposed route in that they would parallel 

Ranson Road (Highway 611) and existing utility rights-of-way to an interconnect with the Gulfstream 

pipeline on the north of the Chevron Pascagoula Refinery. As described in Table 3.6.1-1, both of these 

route alternatives would result in one less waterbody crossing and impact less acres of wetlands than the 

proposed route. Though Route Alternatives B and C would also be collocated with an existing utility and 

transportation rights-of-way along Ranson Road, both would be approximately 1 mile longer than the 

proposed route, which would result in greater total land encumbrances than the proposed route during 

construction and operation. 

Reduction of wetland and waterbody impacts, as well collocation and expansion of an existing 

right-of-way along Ranson Road, would make Route Alternatives B and C environmentally preferable to 

the proposed pipeline interconnect spur route. However, Route Alternatives B and C would also be 

approximately 1 mile longer than the proposed route, which would result in greater total land 

encumbrances during construction and operation, as described in Table 3.6.1-1. Bayou Casotte Energy 

has also indicated that from a constructability perspective, the density of existing natural gas pipelines and 

other infrastructure along Ranson Road would pose technical and safety constraints. In addition, the 

majority of the wetland impacts associated with construction of the proposed interconnect spur would be 

only temporary, as wetlands would be restored following construction (see Section 4.4). Further, the land 

along the proposed interconnect route is already owned or controlled by Chevron, which would avoid 

potential effects to other landowners. For these reasons, Route Alternatives B and C were eliminated 

from further consideration. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Page 3-29 

Figure 3.6.1-1 Proposed Casotte Landing Project 

Route Alternatives to the Proposed Pipeline 

Interconnect Spur 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3-30

TABLE 3.6.1-1 

Comparison of Route Alternatives to the Proposed Pipeline Interconnect Spur 

for the Casotte Landing Project 

Comparative Category Unit Proposed 

Route Alternative A Alternative B Alternative C 

Total pipeline length Miles 1.5 1.6 2.4 2.4 

Construction right-of-waya Acres 15.5 16.5 24.7 24.7 

Permanent right-of-waya Acres 9.1 9.7 14.5 14.5 

Wetland crossingsb Number 3 3 2 3 

Wetlands affecteda, b 

Estuarine emergent Acres 12.9 13.9 2.6 2.6 

Palustrine emergent Acres 2.6 2.6 2.6 7.9 

Waterbody crossingsc Number 2 2 1 1 

Collocation potentiald Percent 0 0 79 79 

_________ 

a Acreages reported assume an 85-foot-wide construction right-of-way and a 50-foot-wide permanent right-of-way. b Estimated from National Wetlands Inventory data. c All potentially affected waterbodies are man-made canals. d This metric evaluates the percentage of the route that would be parallel or adjacent to existing rights-of-way. 

The nonjurisdictional NGL pipeline route proposed by Bayou Casotte Energy would parallel the 

proposed pipeline interconnect spur route before turning north to parallel the existing Gulfstream pipeline 

and MPC transmission line rights-of-way in route to a tie-in with the existing Tri-States NGL pipeline on 

the north side of the Refinery (Figure 3.6.1-1). Because the proposed NGL pipeline would be 

nonjurisdictional, we did not evaluate alternatives for that facility in detail. However, that facility 

represents an interdependent action to the proposed Project, and Bayou Casotte Energy has indicated that 

construction of the NGL pipeline along the proposed route would affect over 25 acres of wetlands and 

require the crossing of five waterbodies. The only other logical route alternative for proposed NGL 

pipeline would parallel Ranson Road to an interconnect on the north of the Chevron Pascagoula Refinery. 

However, for the reasons identified above under our evaluation of Route Alternatives B and C, we do not 

consider that such a route would be technically feasible or preferable to the proposed route. Furthermore, 

the proposed NGL pipeline route would collocate with the proposed interconnect spur, the existing 

Gulfstream pipeline, and an existing transmission line right-of-way for its entire length, thereby 

minimizing the potential for significant environmental consequences and cumulative effects. 

3.6.2 Aboveground Facility Siting Alternatives 

We evaluated the proposed locations of the aboveground facilities associated with the proposed 

pipeline interconnects to determine whether environmental impacts would be reduced or mitigated by use 

of alternative facility sites. The aboveground facilities associated with the proposed pipeline 

interconnects include two meter stations associated with each of the five proposed interconnects with 

existing pipeline systems. Our evaluation involved inspection of aerial photographs and maps and a site 

visit along the proposed pipeline interconnect corridor. One meter station would be associated with the 

four interconnect laterals, and the other meter station would be located at the tie-in between the proposed 

interconnect spur and the Gulfstream pipeline. 

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Because the location of the aboveground facilities would be linked to the location of the pipeline 

interconnects, the search for alternatives was constrained to sites located adjacent to the proposed pipeline 

interconnect route. As described in Section 3.7, each meter station would be located at an interconnection 

with an existing pipeline, and both stations would be contained entirely within existing pipeline rights-ofway. Consequently, construction and operation of the proposed aboveground facilities in those areas 

would represent only a minor change to the existing environmental setting. We did not identify any 

alternative sites for aboveground facilities that would offer a significant advantage to the proposed sites. 

3.7 DREDGED MATERIAL PLACEMENT ALTERNATIVES 

3.7.1 Construction Dredging Placement Alternatives 

As described in Section 2.4.1, construction of the proposed LNG terminal slip would require 

excavation and dredging of about 4.5 mcy of material. Of this total, Bayou Casotte Energy has indicated 

that approximately 1.0 mcy would be excavated above the water table using conventional earth moving 

equipment and used for fill, site leveling, and construction of the hurricane levee at the proposed terminal 

site. As proposed, the remaining 3.5 mcy of material would be dredged from the slip. 

Since late 2005, Bayou Casotte Energy has been working with the regulatory and resource 

agencies to identify a site where it would place this material. Based on these consultations, Bayou 

Casotte Energy has developed a DMMP (see Appendix E). The DMMP provides an analysis of the 

dredging methods and dredge material placement alternatives that Bayou Casotte Energy considered for 

the proposed Project. 

Bayou Casotte Energy evaluated four general alternatives for placement of its initial dredge 

material volumes: 

• confined aquatic disposal; 

• upland confined disposal; 

• beneficial use; and 

• offshore disposal. 

Each of these alternatives is discussed below and depicted in Figure 3.7.1-1. Because dredging 

methods (i.e., mechanical or hydraulic) are largely dependent on the dredge material placement option 

selected, alternative dredging methods were not evaluated independently. 

3.7.1.1 Confined Aquatic Disposal 

Confined aquatic disposal typically involves construction of an earthen or rock berm within an 

open water environment. Dredge material is then placed within the confines of the berm, most often 

using a hydraulic dredge to pump dredge material from the dredge site to the placement site via a 

temporary slurry pipeline. Other options for confinement of materials in aquatic environments do not 

require construction of a containment facility. Containment can sometimes be accomplished by 

excavation and capping of a disposal pit to confine the material. Dredge materials can also be isolated in 

geotextile bags, with the resulting cache of bags capped with suitable material. 

Bayou Casotte Energy indicates that it considered in-channel confined aquatic disposal, but that it 

was not determined to be a practicable application in Bayou Casotte. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Page 3-32 

Figure 3.6.1-1 Proposed Casotte Landing Project 

Dredged Material Placement Alternatives 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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3.7.1.2 Upland Confined Disposal 

As the name implies, upland confined disposal would involve placement of dredge material in an 

upland area that typically consists of an excavated depression that is surrounded by a containment berm or 

dike. If the upland confined disposal site is located in proximity to the dredge site (e.g., within 

approximately 2 miles), dredging would be accomplished with a hydraulic dredge and transported to the 

placement site via a temporary slurry pipeline. If more remotely located, mechanical dredging would be 

used to remove material and load it onto haul trucks for transport to the placement site. Overland hauling 

of dredge material is generally less cost-effective as it results in double handling of material, once at the 

dredge site and again at the placement site. 

Two permitted upland confined disposal sites are located within the vicinity of the proposed 

terminal site. The COE maintains the 136-acre BCDMMS, which is located just south of the proposed 

terminal site. The BCDMMS is an active, dredge material placement site, but it is reserved for disposal 

of maintenance dredge derived materials only, and the COE has confirmed that the BCDMMS would not 

be used for placement of construction dredge material originating from the proposed Project. The 

Chevron Pascagoula Refinery also operates an existing dredge material disposal site, but Bayou Casotte 

Energy has indicated that site is dedicated and permitted solely for the use of maintenance dredging of the 

Refinery’s vessel berths in Bayou Casotte. 

Bayou Casotte Energy also evaluated creation of a new upland confined disposal site. Two 

options were considered. The “North Woods” option would entail construction of a new confined 

disposal site on property within the Refinery complex. The second option would involve construction of 

a new confined disposal site at a location outside the existing Refinery complex. Bayou Casotte Energy 

indicates that both of these options would conceivably be developed within a timeframe compatible with 

the proposed Project and accept the anticipated dredge material volumes. However, both of these options 

would require acquisition or purchase of property, would result in potential traffic related effects due to 

overland hauling of material on public roads, and might result in additional wetland impacts. 

Bayou Casotte Energy also considered placement of dredge materials at existing permitted 

landfills. Such an alternative would also result in potential traffic related effects due to overland hauling 

of material on public roads. Placement at a landfill might also require drying of the dredge materials 

before they would be transported to a landfill, which would result in additional land requirements and 

logistical considerations. 

3.7.1.3 Beneficial Use 

Beneficial use of dredged material allows for recycling of dredged material, particularly that 

material which is not contaminated. If identified as suitable, dredged material may be used for a variety 

of uses including wetland restoration, shore protection, beach nourishment, and land improvement. Two 

studies prepared by the COE Mobile District identified numerous opportunities for beneficial use of 

dredged material along coastal Mississippi (COE 2002b and COE 2003b), and Bayou Casotte Energy, in 

consultation with the COE and MDMR, is exploring the potential for beneficial use of dredge material 

from the proposed Project. Based on consultations to date, Bayou Casotte Energy has identified three 

beneficial use projects that have reasonable capacity, are located within a reasonable distance of the 

proposed Project, and have the potential to use the types of dredged material that would be generated by 

construction activities. These projects include the Round Island Restoration, the Greenwood Island 

Restoration, and the South Wetland Restoration. 

Bayou Casotte Energy developed a Sampling and Analysis Protocol (SAP) in consultation with 

the resource agencies, which was used to conduct suitability testing of the slip dredge material and assess 

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its suitability for various material placement alternatives, including the identified beneficial use projects. 

A summary of the physical, chemical, and biological testing that was conducted by Bayou Casotte Energy 

is provided in Section 4.2.2. In general, it was determined that exposure to the dredge material would 

have little or no adverse effect on the marine environment. Final determination of the dredged material 

suitability for beneficial use would be subject to approval by the COE and MDMR, the agencies with 

evaluation and permitting responsibilities for the three beneficial use sites in proximity to the proposed 

Casotte Landing Project. However, even if determined suitable, the identified beneficial use projects may 

be unavailable to receive the proposed Project’s construction dredged materials as each site is located 

within and would affect Gulf sturgeon critical habitat.

3.7.1.4 Offshore Disposal 

As described in Section 2.4.1, Bayou Casotte Energy proposes to accomplish dredging of the 

terminal slip using a mechanical dredge and place the material in barges or scows for transport to the 

EPA’s permitted Pascagoula ODMDS, which is located in the Gulf of Mexico south of Horn Island. The 

placement of dredged sediments at the ODMDS was evaluated in an EIS prepared by the EPA (1991), in 

coordination with the U.S. Navy and COE. At that time, the COE required a placement site for spoils 

resulting from maintenance dredging within the federal shipping channel extending from the Gulf of 

Mexico to Mississippi Sound, the Pascagoula River, and Bayou Casotte. The EPA concluded that 

impacts associated with placement of dredged materials in the ODMDS would be localized to the vicinity 

of the placement site and would not result in significant adverse effects to the environment. Additionally, 

the ODMDS is located outside of Gulf sturgeon critical habitat. 

Projects involving the transport of material from the United States for the purpose of final 

placement in ocean waters must be evaluated pursuant to Section 103 of the MPRSA to determine 

whether discharge of those materials would unreasonably degrade or endanger human health, welfare, or 

the marine environment. Per Section 103 of the MPRSA, the COE is the permitting authority for dredged 

material placement, subject to EPA concurrence. Based on consultations and sediment sampling and 

analysis completed to date (see Section 4.2.2 and Appendix E), Bayou Casotte Energy indicates that its 

construction dredge material would qualify for placement at the ODMDS and has identified this as its 

preferred alternative for construction dredge material placement. The Commission and Bayou Casotte 

Energy are therefore proceeding under the assumption that the dredge materials would be suitable for 

placement at the ODMDS. However, Bayou Casotte Energy has not yet obtained the final COE and EPA 

approvals required pursuant to Section 103 of the MPRSA to authorize this plan (see Section 4.2.2). 

3.7.2 Maintenance Dredging Placement Alternatives 

According to preliminary modeling, Bayou Casotte Energy estimates that maintenance dredging 

of the proposed terminal slip would generate up to about 250,000 yd3

 of material per year during 

operations, as described in Section 2.7.1. The maintenance dredge material placement alternatives that 

would be considered would be the same as those identified in the above analysis of construction dredging 

placement alternatives, though additional or different beneficial use projects would be identified in the 

future. 

Bayou Casotte Energy indicates that it would consider use of one or more beneficial use sites for 

placement of maintenance dredge materials, based on availability of suitable sites and timing 

considerations (i.e., whether needs for beneficial use materials and maintenance dredging schedules 

aligned). However, there are currently no beneficial use sites that would reasonably be relied on for longterm periodic placement of maintenance dredged material. Consequently, Bayou Casotte Energy has 

identified placement of maintenance dredge materials at the Pascagoula ODMDS as its preferred 

alternative. 

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3.7.3 Conclusions Regarding Dredged Material Placement Alternatives 

Bayou Casotte Energy indicates that its preferred alternative for placement of both construction 

and maintenance dredge materials is placement at the ODMDS, with contribution to beneficial use sites as 

available. While we encourage contribution of dredge materials from the proposed Casotte Landing 

Project, we also recognize that availability of compatible beneficial use projects and alignment of 

schedules would not be entirely within the control of Bayou Casotte Energy. 

As described in Section 3.7.1.4, the ODMDS was initially designated for receipt of maintenance 

dredge materials from Bayou Casotte. Additionally, the environmental effects of dredge material 

placement at the ODMDS have already been determined to be less than significant (EPA 1991). 

Therefore, pending receipt of the required approvals under Section 103 of the MPRSA noted previously, 

we do not consider any of the dredge material placement alternatives evaluated to represent a technically 

or environmentally preferable alternative to Bayou Casotte Energy’s preferred dredged material 

placement plan. 

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4.0 ENVIRONMENTAL ANALYSIS 

The environmental consequences of constructing and operating the proposed Casotte Landing 

Project, including impacts from the operation of LNG marine traffic in the waterway from the territorial 

seas to the berthing areas at the facility, would vary in duration and significance. Four levels of impact 

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

generally occur during construction with the resource returning to preconstruction conditions almost 

immediately afterward. Short-term impacts would continue for up to three years following construction. 

Impacts were considered long term if the resource would require more than three years to recover. A 

permanent impact would 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 an 

LNG terminal. We considered an impact to be significant if it would result in a substantial adverse 

change in the physical environment. 

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

impacts, and proposed mitigation for each resource. Bayou Casotte Energy, as part of its proposal, agreed 

to implement certain measures to reduce impacts. We evaluated Bayou Casotte Energy’s proposed 

mitigation to determine whether additional measures are necessary to reduce impacts. 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 Bayou Casotte 

Energy. 

Conclusions in this EIS are based on our analysis of the environmental impacts and the following 

assumptions: 

• Bayou Casotte Energy would comply with all applicable laws and regulations; 

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

• Bayou Casotte Energy would implement the mitigation measures included in the application 

and supplemental filings to the FERC. 

4.1 GEOLOGY 

4.1.1 Geologic Setting 

The proposed Casotte Landing Project is located on Bayou Casotte within the East Gulf Coast 

Plain Physiographic Region, specifically the Coastal Zone, which is a low-lying 5 to 30-mile wide region 

of slight relief. The topography is gently undulating to flat, with elevations below 50 feet in most areas. 

The Coastal Zone is composed of several active, natural systems that include fluvial-deltaic and bayestuary-lagoon depositional environments. Similar coastal systems have existed in the past, as indicated 

by older sedimentary deposits. The positions of the various coastal processes and resulting sedimentary 

deposits have shifted over time due to transgressive and regressive events that have occurred since the 

Jurassic Period. Vegetated and stabilized sand ridges of former beach dunes are occasionally found near 

the coast, with a height between 10 and 15 feet. 

The gulf coastal plain is characterized by thick sequences of unconsolidated to semi-consolidated 

Cenozoic sediments several hundred feet thick. At a given temporal horizon, these sediments of sand, 

silt, and clay represent depositional environments ranging from nonmarine in outcrop areas away from the 

coast to marine towards the coast. The gulf coastal plain began developing in the middle Jurassic Period 

during a major transgression. Transgressive and regressive events occurred throughout the Cretaceous 

period, at which time carbonate and salt layers were deposited. During the late Cretaceous and early 

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Tertiary Periods, large volumes of siliciclastic sediment from the west was deposited in the gulf coastal 

plain, with the place of deposition moving from the Mississippi Embayment south to the Gulf Coast Basin 

over time. Salt domes began forming in the Tertiary Period and ceased forming during the Oligocene 

Epoch in the Quaternary Period. 

Two different types of surficial soil deposited during the Holocene Epoch are present at the 

Project site: fill and surficial sand. The fill is generally present to depths of 6 feet below ground surface 

(bgs) and consists of gray to light brown, loose to very dense, dry to moist, clayey sand with gravel and 

shell fragments (URS 2005). The surficial sand contains interbedded silts and clays and is present to 

depths of 12 feet bgs. The surficial sand is well to poorly graded, fine grained, and has an in-situ 

moisture content of 21 percent. The median value of silt and clay is 27 percent. Underlying the surficial 

soil is the Holocene-aged upper clay unit. The upper clay unit is generally present from 12 to 42 feet bgs. 

The upper clay unit is soft to very soft, dark gray to green, moist to wet, high plasticity clay with traces of 

fine sand, shell, and wood fragments (URS 2005). The median in-situ moisture content is 54 percent and 

the median sand content is 5 percent. This unit is a partially confining aquifer. 

Underlying the upper clay unit is the interbedded sandy clay to clayey sand unit of the 

Pleistocene-aged Terrace Deposit. This unit is generally present between 42 and 49 feet bgs. This unit is 

a confined aquifer with an average gradient of 0.002 feet/feet (ft/ft) to the northwest toward Bayou 

Casotte. The lower clay layer of the Pleistocene-aged Terrace Deposit is found between 49 and 107 feet 

bgs. The lower clay layer has a median sand content of 3 percent and a median in-situ moisture content 

of 57 percent. From 107 to 120 feet bgs is a layer of interbedded sands and clays underlying the Terrace 

Deposit in the Citronelle Formation, which dates from the Pliocene-Pleistocene Epochs of the Quaternary 

Period. The Citronelle Formation is a dense sand present from approximately 120 to 240 feet bgs. 

Underlying the Citronelle Formation is the Graham Ferry, a stiff clay layer that dates from the Miocene 

Epoch, found from 240 feet bgs to a depth of over 600 feet bgs. 

The existing topography at the 259.4-acre LNG terminal site would be permanently changed by 

the excavation and dredging of an unloading slip for the marine terminal. The unloading slip, situated 

along Bayou Casotte, would be 900 feet wide by 1,450 to 2,150 feet long and 42 feet below MLLW. 

Additional land modification at the proposed LNG terminal site would include grading the remainder of 

the site to a finished elevation of approximately 11 feet NGVD and building an earthen hurricane levee 

14 feet above grade around the LNG storage tanks. Topographic contours would also change at locations 

where materials dredged from the unloading slip are disposed. Details of these modifications, including 

volumes of material to be excavated and dredged, are discussed in Section 2.4. 

Construction and operation of the proposed pipeline interconnects would not materially alter the 

geologic or natural topographic conditions in the pipeline interconnection Project areas. The natural 

topographic slope and contours would be temporarily altered along much of the pipeline route by grading 

and trenching activities. However, Bayou Casotte Energy would restore topographic contours and 

drainage conditions to the extent practicable to preconstruction conditions following installation of the 

pipeline interconnects, except at those locations where permanent changes in drainage would be required 

to prevent erosion, scour, and possible exposure of the pipeline interconnection. 

4.1.2 Mineral Resources 

Primary mineral resources that have been developed in Mississippi are sand and gravel, crushed 

stone, and portland cement for construction uses and petroleum. 

An analysis of aerial photographs and topographic maps indicates that no sand or gravel mining 

operations are found near the proposed Project site. The only coal mine in Mississippi is located near the 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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middle of the state; therefore, the proposed terminal and pipeline interconnects are not expected to have 

an impact on future exploitation of these resources. 

Oil refineries and the associated crude oil, product, and liquified petroleum gas pipelines are 

present in the vicinity of the proposed Project site. One abandoned oil well and two natural gas wells 

with expired permits are located in Jackson County, but are several miles from the proposed Project site 

(Mississippi State Oil and Gas Board 2005). Therefore, Project facilities are not expected to interfere 

with petroleum production in the area. 

4.1.3 Geologic Hazards 

Potential geologic hazards in the Project area consist of seismic-related hazards, soil liquifaction, 

landslides, and subsidence. Slope instability and inadequate load-bearing capacity of soils would also 

pose a hazard at the proposed LNG terminal. Conditions necessary for the development of other geologic 

hazards, including karst terrain, avalanches, and volcanism are not present in the proposed Project area. 

In general, the potential for geologic hazards to significantly affect the construction or operation 

of the proposed Project is low. The risk of damage resulting from geologic hazards would be avoided or 

reduced by specific engineering design criteria, ground modification, other construction techniques, and 

operating procedures to be implemented by Bayou Casotte Energy. Geologic hazards, their potential to 

occur in the Project area, and proposed mitigation measures, where applicable, are discussed below. 

4.1.3.1 Seismicity and Faulting 

Potential seismic-related hazards include earthquakes, surface faulting, soil liquefaction, and 

related soil failures. The Gulf Coast region of the United States is tectonically stable and the likelihood of 

a major earthquake occurring in the Project area would be very low. Seismic risk can be quantified by the 

motions experienced by the ground surface or structures during a given earthquake, expressed in terms of 

the acceleration due to gravity (g). The USGS has developed a series of maps for the entire United States 

that describe the likelihood for shaking of varying degrees to occur in a given area (USGS 2002). 

According to the USGS maps, there is a 10 percent probability of an earthquake occurring in the next 

50 years that would result in a peak ground acceleration rate of about 0.01 g in the Project area. A peak 

ground acceleration of 0.1 g is generally considered to be the minimum threshold for damage to older 

structures or structures not made to resist earthquakes (USGS 2004). 

Although the number of earthquakes that have epicenters in Mississippi are few, the state has 

been affected by earthquakes in neighboring states, including a series of great earthquakes near New 

Madrid, Missouri in 1811 and 1812. The closest historical earthquake was located 36 miles west of the 

Project site and occurred February 1, 1955. The Pickens-Gilbertown and the Southern Arkansas fault 

zones occupy an area over 500 miles long and 25 miles wide, running from southwestern Alabama 

through west-central Mississippi to southern Arkansas and eastern Texas. The closest that the zones 

come to the Project site is 43 miles. The formations overlying the Pickens-Gilbertown fault zone are 

unfaulted indicating that the fault zones are no longer active. Deep exploration wells indicate that the 

Southern Arkansas fault zone has been inactive since the Miocene Epoch. These faults are not anticipated 

to have an impact on the proposed Casotte Landing Project. 

4.1.3.2 Soil Liquefaction 

Secondary seismic effects triggered by strong ground shaking are often more serious than the 

shaking itself. The most damaging secondary seismic effect is often soil liquefaction, a physical process 

in which saturated, non-cohesive soils temporarily lose their bearing strength when subjected to strong 

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and prolonged shaking. Soils most prone to liquefaction are poorly graded, or in other words, have a 

uniform grain size. Soil liquefaction can also lead to other ground failures, including settlement and 

lateral spreading. 

A geotechnical survey was conducted to assess the potential for liquefaction at the proposed 

Project site. Boring logs and Cone Penetrometer Test (CPT) results were evaluated to identify layers that 

were susceptible to liquefaction. Although the CPT results found liquefiable layers at the proposed 

Project site, these thin sand layers were not laterally extensive enough to impact the Project. Earthquake 

stress potential and subsurface stress resistance were compared to develop a factor of safety values for the 

Project site. The factor of safety values were greater than or equal to one, which is satisfactory. Based on 

these facts, there is a relatively low potential for seismically-induced liquefaction to occur at the proposed 

Project site. 

4.1.3.3 Landslides/Slope Stability 

Landslides are a form of ground failure, involving the down-slope movement of earth materials 

under the force of gravity due to natural or artificial causes. The proposed Project area is located in a 

zone of low susceptibility and low incidence of natural landslides. Landslides from artificial causes due 

to construction of the proposed terminal have a low probability of occurring due to engineering and 

construction standards that would be applied at the site. 

The geotechnical study indicated that the uppermost soils at the proposed LNG terminal site have 

very low load-bearing capacities due to the very soft and cohesive soils and loose granular soils occurring 

within the upper 35 to 55 feet. Therefore, soil improvements and engineering designs must be 

implemented to ensure the stability of the LNG storage tanks, process structures, and marine facilities. 

The proposed LNG tanks would be supported on mat foundations with a re-consolidation of the existing 

soils under the mat or pile-supported foundations. Pilings for any structures that would impose a 

significant foundation load (such as LNG storage tanks, vessel berth pilings) would be driven to depths 

ranging from 90 to 120 feet bgs. The foundations would be monitored to ensure that no ground failure 

under the LNG tanks is occurring. 

The proposed process area would include excavations of the main and secondary impoundment 

sumps. Groundwater control would be necessary to prevent slope failure during the excavations. 

Short and long-term stability of the sloped walls of the marine slip has been analyzed to 

determine if failure would occur. The structures associated with the marine facilities would be supported 

with both vertical and battered piles. A 5:1 slope would be created from the crest of the slope to the toe 

of the slope. According to the results of a slope stability analysis for the LNG terminal site, the proposed 

slope configuration would meet safety criteria. Provided that all engineering specifications are followed, 

the marine slip would not likely be affected by landslides or other slope failures. 

4.1.3.4 Subsidence 

Subsidence would be likely to occur at the site due to the settling of geologically recent alluvial 

material in low-lying coastal areas. The rate of subsidence at the proposed Project site is approximately 

2 millimeters per year (Berger 2005). Because the structures at the proposed Project site would make use 

of pile-supported foundations, impacts from subsidence would unlikely affect the Project facilities. 

Two public water supply wells are located within 1 mile of the proposed Project area. Based on 

current groundwater usage in the Project area, subsidence in the Project area resulting from groundwater 

extraction is minimal. No wells are planned for installation at the proposed site. 

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4-5 

Due to limited production of oil and gas in Jackson County, subsidence associated with oil or gas 

production in the area is not anticipated. 

4.1.3.5 Flooding/Storm Damage 

The Mississippi Gulf Coast is susceptible to hurricanes and tropical storms, which may produce 

storm surge, flooding, and high winds. Storm surge, the abnormal rise in sea level due to the wind and 

pressure forces associated with hurricanes and other tropical storms, is often the most significant cause of 

damage to facilities and property in low-lying coastal areas. Freshwater flooding can occur along rivers, 

stream valleys, and adjacent, poorly-drained areas. 

Flash Flooding 

The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Maps show the 

majority of the Project site is within the FEMA 100-year floodplain. Two areas on the north and western 

portion of the site are above the 100-year floodplain. The potential for flash flooding to significantly 

impact construction or operation of the proposed Project is low. The greatest potential for flash flooding 

to occur in the Project area is associated with tropical storms and hurricanes, which are usually 

accompanied by significant precipitation over a short period of time. Aside from temporary delays during 

the construction phase of the Project, the primary potential impact associated with flooding would be soil 

erosion. 

The potential effects associated with high rainfall events during construction would be mitigated 

by implementing Bayou Casotte Energy’s Upland Erosion Control, Revegetation, and Maintenance Plan 

(Plan), as modified in this EIS (Appendix B). After construction, the Project area would be stabilized 

with permanent erosion control measures such as berms and vegetative cover, including revegetation of 

disturbed soils. These measures would minimize the effects of high rainfall events during operation of 

the proposed LNG terminal and pipeline. 

Hurricane Storm Surge 

Bayou Casotte Energy used three models to assess future hurricane storm surge events: the 

FEMA Flood Insurance Study Model (FIS) from 1987; an analysis conducted by Chevron in 1998; and 

the COE Hurricane Surge Atlas in 1999. The FEMA FIS analyzes the effect of tropical storms and 

hurricanes from the storm of 1909 to Hurricane Frederic in 1987. The analysis had two parts: evaluation 

of the still water level and computation of the related wave set up. In the vicinity of the proposed 

terminal site, the 100-year still water elevation was found to be 9.0 feet NGVD and the wave crest 

elevation was 13.4 feet NGVD. The base flood elevation is from 9.0 to 13.0 feet NGVD. 

The Chevron analysis was conducted after Hurricane Georges flooded the Pascagoula Refinery in 

1998. The 100-year still water elevation at the Pascagoula Refinery was found to be 11.1 feet NGVD. 

The required levee crest elevation would be 18.1 feet NGVD for a 100-year storm and 22.8 feet NGVD 

for a 500-year storm, which is the design basis for the levees at the proposed Casotte Landing site. 

The COE Hurricane Surge Atlas was developed to be used for evacuation applications and 

typically is more conservative. Storm surge elevations are calculated based on the maximum envelope of 

water (MEOW) from all storm surge models and is per the Safir-Simpson scale hurricane ranking. For a 

Category 5 storm, the MEOW is 22.2 feet, which is less than the design elevation of the levees at the 

proposed Project site. 

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Bayou Casotte Energy has collected historic oceanographic data on the effects of hurricanes in 

the Project area and currently collects data during hurricanes to update the analysis. With the recent strike 

of the Mississippi coast by Hurricane Katrina (August 2005), Bayou Casotte Energy was able to update 

its design basis for construction of the hurricane levee. Based on this data, wave and storm surge would 

be of concern at the proposed Project site.

In order to mitigate the potential hazards associated with storm-induced flooding and waves, 

Bayou Casotte Energy would construct a hurricane levee to surround the terminal process equipment and 

LNG storage tanks. The hurricane levee crest construction height is proposed at 24 feet NGVD to allow 

for an adequate margin of safety at the proposed Project site. 

4.1.3.6 Shoreline Erosion 

The shoreline along the Gulf Coast exists in various states of erosion, accretion, and equilibrium. 

These processes are dynamic and vary with time as well as location. The existing shoreline at the 

proposed LNG terminal has been significantly modified. The geotechnical study for the proposed Project 

presented aerial/satellite photographs over time that show shoreline erosion is removing significant 

coastal segments of the immediate coastal shoreline to the south and east of the proposed terminal 

facilities. 

As discussed in Section 4.1.1, the shoreline would be altered at the proposed LNG marine 

terminal by construction of a marine unloading slip. The new shoreline would be protected from erosion 

by measures taken to stabilize the slope parallel to the shoreline to minimize scour potential within the 

berth area from LNG ship propeller wash. During the transit along the Bayou Casotte Channel, LNG 

marine traffic would be operating at low speeds and would not create wakes that would increase the 

potential for shoreline erosion in the Project area, or along the transit waterway between Horn Island and 

Petit Bois Island. The implementation of the shoreline scour protection in the berth area would minimize 

the potential for shoreline erosion associated with the Project. 

4.1.4 Blasting 

Based on the regional and local geology, no areas of shallow bedrock are present. As a result, no 

blasting is anticipated for development of the proposed Casotte Landing Project. 

4.1.5 Paleontological Resources 

Numerous fossils of marine origin are present in the coastal deposits of Mississippi. Most of 

these fossils originate from the Cenozoic Era. Principal deposits of buried reef shell occur in the 

Mississippi Sound. However, because of the relatively recent deposition of the surficial geology that 

would be encountered at the site, it is unlikely that fossils would be encountered at the site. 

4.2 SOILS AND SEDIMENTS 

4.2.1 Soil Resources 

We reviewed information provided by Bayou Casotte Energy and contained in the U.S. 

Department of Agriculture (USDA), Natural Resources Conservation Service (NRCS) Soil Survey 

Geographic (SSURGO) database for Jackson County, Mississippi (NRCS, USDA 2005a) to evaluate 

likely project-related impacts on soils within the proposed LNG terminal site as well as along the 

proposed pipeline interconnect routes and associated aboveground facilities. Soils at the proposed LNG 

terminal site would be disturbed by grading, excavation, heavy equipment traffic, and the construction 

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and operation of aboveground facilities. Soils at the proposed terminal site would also be physically 

removed to construct the marine terminal. Soils along the proposed pipeline interconnect routes would be 

disturbed by grading, excavation, and heavy equipment traffic. Issues to be addressed include permanent 

conversion of prime farmland to other uses, soil compaction, erosion and sediment control, and long-term 

soil productivity. 

Bayou Casotte Energy’s Plan and Procedures, as modified in this EIS, would be implemented to 

address potential impacts on soil resources in the Project area. Some of the relevant mitigation measures 

specified in Bayou Casotte Energy’s Plan and Procedures include requirements to: 

• segregate a maximum of 12 inches of topsoil in all actively cultivated or rotated croplands, 

pastures, residential areas, hayfields, and at other areas at the request of the landowner or land 

management agency; 

• provide temporary erosion and sediment control measures such as silt fence, straw bales, 

slope breakers, seeding, mulch, and erosion control fabric to minimize any impacts related to 

soil erosion and sedimentation that may result from precipitation runoff; 

• mitigate soil compaction following construction and right-of-way restoration activities; 

• ensure revegetation of all areas disturbed by Project-related activities. Disturbed upland areas 

would be seeded in accordance with written recommendations from local conservation 

authorities or as requested by the landowner; 

• provide post-construction monitoring of mitigation practices to ensure their success; 

• implement the SPCC Plan if a spill or leak occurs during construction; and 

• utilize at least one EI to ensure implementation of the practices outlined above. 

In response to past concerns raised by federal, state, and local agencies, the FERC developed a 

Plan to provide baseline mitigation measures for minimizing erosion and enhancing revegetation during 

construction. The FERC's Plan includes requirements for pre-construction planning, environmental 

inspection, specific construction methods, sediment and erosion control, restoration, and 

post-construction maintenance. Bayou Casotte Energy has requested certain variances from the FERC's 

standard Plan. In the case of construction activities at the terminal site, uplands would not simply be 

crossed and then restored; rather they would be filled, graded, or otherwise completely removed. Because 

of the large-scale, permanent modification of the proposed terminal site, we recognize that certain 

construction activities would be required within and immediately adjacent to existing uplands. Due to 

this feature of the proposed Project, some of the standard measures in the FERC's Plan would not be 

applicable at the proposed LNG terminal site including restoration, revegetation, and post-construction 

monitoring and maintenance. 

The FERC's acceptance of these requested variances applies only to the proposed LNG terminal 

site. Other areas that would be affected by construction of the proposed pipeline interconnects must 

comply with the FERC's standard Plan, regardless of whether access is obtained via easement agreement. 

Additionally, Bayou Casotte Energy proposed several variances that are relatively minor 

modifications, reflect consideration of site conditions, and that offer similar levels of environmental 

protection as provided by the FERC's Plan. Those measures, which are approved, include: 

• the nominal construction right-of-way of 110 feet in upland locations along the pipeline 

route. The expanded construction right-of-way is needed due to the containment of a dual 

pipeline configuration. We agree that the wider construction right-of-way for the collocation 

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of pipelines in uplands would accommodate the workspace requirements and safety 

considerations for construction personnel (Section IV.2); 

• extending each temporary slope breaker marginally off the disturbed right-of-way so that the 

outfall exits onto stable, well vegetated areas. If a stable, well vegetated area does not exist, 

an energy dissipater would be constructed at the end of the slope breaker (Section IV.F.1.c); 

and 

• openings would be left in sediment barriers to allow temporary and permanent slope breakers 

to exit the construction right-of-way (Section IV.F.2.c). 

Additionally, Bayou Casotte Energy proposed numerous other variances from the FERC's Plan 

that either were not sufficiently supported or did not offer similar levels of environmental protection. 

These other proposed variances have been rejected. Therefore, we recommend that: 

• Except for the proposed variances specifically approved above, Bayou Casotte Energy 

should revise its proposed Plan to be consistent with the FERC's standard Plan, as 

modified in this EIS. The revised Plan should be filed with the Secretary for review and 

written approval by the Director of OEP prior to construction. 

4.2.1.1 Soil Characteristics 

Soils in the proposed Project area are generally medium to fine textured and formed in alluvium. 

Major characteristics of soils associated with the proposed LNG terminal and proposed pipeline 

interconnects are presented in Table 4.2.1-1. The majority of the soils at the proposed terminal site 

consist of fill, or altered soils from previous dredge disposal operations and industrial uses. Most of the 

soils along the proposed pipeline interconnects and NGL pipeline are hydric and poorly drained, although 

there are small areas of well drained soils. Generally, the landscape is nearly level except near the 

shoreline. Soil erosion is not a major concern on the soils of the proposed Project area because the 

landscape is nearly level. 

LNG Terminal Facilities 

According to the current NRCS soil survey database, soils at the proposed LNG terminal site are 

comprised of the Udorthents and Axis soil series. Udorthents soils comprise 64 percent of the proposed 

terminal site. These soils are disturbed soils primarily consisting of fill material. This is verified by the 

very soft to soft clays and very loose to loose sands and silts encountered in the upper 35 to 55 feet of the 

geotechnical soil borings conducted throughout the proposed terminal site. The Axis soils formed in 

thick loamy marine sediments on coastal marshes. 

The construction of the proposed LNG terminal facilities would involve removing the existing 

surface soils to expose the most stable subsoils. Fill would be used to raise the surface grade where the 

proposed LNG terminal would be constructed, with the exception of the LNG storage tank area, which 

would be lower in elevation for secondary containment purposes. Additional soil amendments would also 

be used to re-engineer the soils at the site to provide a stable land surface for construction. These 

activities would not have a significant impact on soils at the proposed LNG terminal site because these 

soils were already impacted by previous fill and industrial activities. Because the soils within the 

proposed LNG terminal would be permanently converted to an industrial use following construction, 

mitigation of compaction impacts on soils at the terminal would not be necessary. 

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TABLE 4.2.1-1 

Major Characteristics of Soils Impacted by the Proposed Casotte Landing LNG Project 

Soil Series 

Acreage 

Impacted 

Drainage 

Class 

Prime 

Farmland Hydric Soils

High 

Compaction 

Potential 

Highly 

Erodable 

Soils 

Poor 

Revegetation 

Potential 

LNG Terminal 

Udorthents 164.9 Varies No Unranked Varies No Yes 

Axis Mucky 

Sandy Clay 

Loam, frequently 

flooded 

69.0 Very poorly 

drained 

No Yes No No No 

Water 25.5 NA NA NA NA NA NA 

Pipeline Spur Interconnect 

Udorthents 2.1 Varies No Unranked Varies No Yes 

Axis Mucky Sand 

Clay Loam, 

frequently 

flooded 

15.3 Very poorly 

drained 

No Yes No No No 

Nonjurisdictional Facilities 

Udorthents 23.9 Varies No Unranked Varies No Yes 

Axis Mucky Sand 

Clay Loam, 

frequently 

flooded 

4.9 Very poorly 

drained 

No Yes No No No 

Bayou Sandy 

Loam, 0-1% 

slopes 

7.4 Very poorly 

drained 

No Yes No No No 

__________ 

Source: SSURGO database 

Pipeline and Associated Aboveground Facilities 

The proposed interconnect and NGL pipelines would cross the Udorthents, Axis, and Bayou soil 

series. Udorthents and Axis soils were described in the previous section. Bayou soils consist of sandy 

loam that is poorly drained and also formed on loamy sediments, such as Axis soils. 

Pipeline construction activities such as clearing, grading, trench excavation, backfilling, and the 

movement of heavy construction equipment along the construction right-of-way would result in adverse 

impacts on soil resources. Clearing activities remove the protective cover and expose the soil to the 

effects of wind, sun, and precipitation. This exposure would lead to movement of sediment to sensitive 

areas. Grading and equipment traffic have the potential to compact soil, reducing porosity and infiltration 

rates, which would lead to increased runoff potential or difficulty in revegetating. Trench excavation and 

backfilling would lead to a mixing of the soil layers, bringing potentially less productive subsoil to the 

surface or introducing rocks from deeper horizons to the soil surface. The soils would also potentially be 

impacted due to contamination from spills or leaks of fuels, lubricants, and coolants from construction 

equipment. 

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4.2.1.2 Prime Farmland 

As part of our review, we considered the effect of the proposed Project on prime farmland. 

Specifically, we evaluated the extent to which construction of aboveground facilities would result in the 

loss of prime farmland through permanent conversion to other uses. Prime farmland is designated by the 

NRCS and has the best combination of physical and chemical characteristics for producing agricultural 

crops with the minimum inputs of fuel, fertilizer, pesticides, and labor. Prime farmland typically: 

• contains few or no rocks; 

• is not subject to excessive erosion; 

• is relatively permeable to air and water; and 

• is not subject to prolonged periods of flooding during the growing season. 

No prime farmland has been designated in the proposed Project area by the NRCS; therefore, the 

construction of the proposed LNG terminal and proposed pipeline interconnects would not impact prime 

farmland. 

4.2.1.3 Hydric Soils 

Hydric soils, as designated by the NRCS, are formed under saturated conditions and are a 

component in determining the presence of jurisdictional wetlands. A high incidence of hydric soils would 

suggest a high probability of potential impacts on wetlands. A review of NRCS data indicates that hydric 

soils comprise 88 percent of the pipeline spur interconnect route and 34 percent of the NGL pipeline route 

(see Table 4.2.1-1). Approximately 27 percent of the soils at the proposed LNG terminal site are 

classified as hydric. 

The extent of hydric soils suggests that proposed Project-related impacts on wetlands would be 

extensive (see Section 4.4). In addition, high groundwater levels associated with hydric soils would 

create a buoyancy hazard for the pipeline interconnects. In accordance with its Procedures, Bayou 

Casotte Energy would minimize rutting of hydric soils by using construction mats where hydric soils 

cannot support equipment and/or employing low-ground-weight equipment. Special construction 

methods such as concrete coating of pipe and other weighting methods would be used to overcome 

buoyancy hazards during operation of the pipeline. 

4.2.1.4 Compaction Potential 

Soil compaction increases soil density, degrades soil structure, and reduces the permeability of 

the soil to air, water, and plant roots. The decreased permeability increases runoff and erosion and 

reduces overall productivity. Fine textured soils with poor internal drainage are the most susceptible to 

compaction by construction equipment and vehicles. Wet conditions at the time of construction increase 

the potential for compaction to occur. 

The majority of the soils at the proposed LNG terminal and along the proposed pipeline 

interconnects do not have a high potential for compaction. Impacts from compaction would be minimized 

by implementing measures outlined in Bayou Casotte Energy’s Plan and Procedures, as modified in this 

EIS, (for example, use of construction mats or low-ground-weight equipment) during construction in soft 

or wet soils. Additionally, the EI would restrict construction activities during unfavorable conditions 

(such as wet weather) to further reduce compaction. Compaction impacts would be mitigated through the 

use of deep-tillage implements during restoration activities. 

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4.2.1.5 Erosion 

Soil that is disturbed by construction activities has an increased risk of erosion by wind and 

water. Erosion not only causes the loss of high quality topsoil, but generates sediment that can degrade 

wetlands or waterbodies. The Project area has very level topography, so according to SSURGO data, 

most of the soils have a low potential for erosion under normal land use. Construction activities cause 

more severe soil disturbance than normal land use, which in turn increases the erosion potential. Exposed 

soils coupled with heavy rainfalls that are common in the Project area would result in significant erosion 

and sedimentation if appropriate controls are not in place. 

Bayou Casotte Energy’s Plan contains a number of provisions to control erosion and 

sedimentation such as silt fence, straw bales, slope breakers, seeding, mulch, and erosion control fabric. 

Bayou Casotte Energy also indicates that sediment traps and physical barriers would be installed as 

needed. These techniques, when properly installed, inspected, and maintained, would minimize any 

impacts related to soil erosion and sedimentation that may result from precipitation runoff. Additionally, 

Bayou Casotte Energy has developed a site-specific SWPPP as a requirement of the general permit for 

construction stormwater discharge that details the Best Management Practices (BMP) to be used during 

construction (see Appendix C). Shoreline erosion at the LNG terminal site and along the waterway that 

would be used by the LNG marine traffic is addressed in Section 4.1.3.6. 

As a requirement of coverage under the National Pollutant Discharge Elimination System 

(NPDES) Industrial Stormwater General Permit, an Industrial SWPPP would be required. The Industrial 

SWPPP would be submitted to the MDEQ, along with an application for coverage, at least 60 days before 

commencement of facility operations to allow for agency review. The Industrial SWPPP would, in part, 

identify areas with a high potential for soil erosion and specify prevention measures to limit erosion. This 

plan would be updated on an as-need basis, at least annually, in accordance with the terms of the general 

permit.

4.2.1.6 Revegetation 

Successful revegetation is probably the most effective way to achieve permanent erosion control 

in areas that are not active cropland. The SSURGO database indicates that the Axis series soils have 

good revegetation potential, but that the Udorthents soils have a poor revegetation potential. Udorthents 

are soils that have been disturbed by human activity and can have widely varying properties. The 

majority of Udorthents soils are located on the proposed LNG terminal property. 

Bayou Casotte Energy is proposing to revegetate only the areas that are covered under an 

easement agreement, which would exclude the proposed terminal property. Much of the proposed 

terminal site would be covered by gravel or crushed rock, or be paved. Some small areas would be 

covered with primarily ornamental/lawn vegetation. Therefore, the poor revegetation potential of 

Udorthents soils would not be an issue. On those areas covered under an easement agreement, Bayou 

Casotte Energy’s proposed Plan and Procedures, as modified in this EIS, would be utilized to revegetate 

the land. The local soil conservation authority would be consulted to determine the appropriate soil 

additives and seeding requirements. Moreover, Bayou Casotte Energy’s Plan and Procedures call for 

post-construction monitoring to assess the success of revegetation, as well as continued efforts until 

revegetation is successful. 

4.2.1.7 Soil Contamination 

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

would adversely affect soils. The effects of contamination are typically minor because of the low 

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frequency and volume of spills and leaks. Bayou Casotte Energy has developed a SPCC Plan for 

construction that specifies cleanup procedures in the event of soil contamination from spills or leaks of 

fuel, lubricants, coolants, or solvents. Bayou Casotte Energy would implement its SPCC Plan to prevent 

and contain, if necessary, accidental spills of any material that may contaminate soils, and to ensure that 

inadvertent spills of fuels, lubricants, or solvents are contained and cleaned in an appropriate manner (see 

Appendix D). 

The proposed terminal site was owned and operated by Corning Glass Works (Corning), who 

subleased portions of the property to Cohart Refractory (Cohart). Cohart manufactured high-temperature 

brick created by using a magnesite refractory from 1955 through 1989. An unlined below-grade landfill 

was used to store furnace dust and discarded ore and two unlined lagoons were used to settle fines in 

wastewater effluent prior to discharge. The landfill was excavated and backfilled with soil and refractory 

brick debris in 1984. The lagoons were filled and capped in 1989. A “No Further Action” designation 

was issued for the Project site by the EPA. An Environmental Site Assessment conducted in 2005 found 

no significant exposure risk. Therefore, contaminated soils would be discovered during construction 

activities; however, the risk appears to be minimal. If contamination is encountered during construction 

activities, Bayou Casotte Energy would instruct the contractor to stop work at the contaminated location 

to allow for the evaluation of potential contamination and to develop a plan for the safe handling and 

disposal of the contaminated materials in accordance with applicable local, state, and federal regulations. 

Bayou Casotte Energy is also in the process of developing a proposed SPCC Plan to cover the 

operational phase of the proposed Project that would include procedures to prevent and mitigate 

accidental releases of oil, gas, lubricants, or hazardous materials. 

4.2.2 Sediments 

Construction of the proposed LNG terminal would require the dredging of about 3.5 mcy of 

sediments to create the marine facilities associated with the proposed Project. The ship berth and 

maneuvering area would be dredged to an elevation of 42 feet below MLLW, with an additional 2 feet for 

advance maintenance and up to 2 feet of potential overdredge allowance. Maintenance dredging would 

require the removal of about 250,000 yd3

 on an annual basis. The dredged material is proposed for 

placement in a combination of offshore (EPA-designated ODMDS) and approved and available federal 

and state coastal or offshore BU project sites. Currently, no BU project sites have been identified as 

being available. 

Projects involving the transportation of dredged material for the purpose of final placement in 

ocean waters outside the 3-mile-limit must be evaluated pursuant to Section 103 of the MPRSA to 

determine whether the proposed discharge would unreasonably degrade or endanger human health, 

welfare or amenities, or the marine environment, ecological systems, or economic potentialities. A 

summary of the physical, chemical, and biological testing that was conducted by Bayou Casotte Energy to 

assist the COE, EPA, and MDMR in evaluating the proposed dredged sediment relative to Section 103 of 

the MPRSA is provided below. Bayou Casotte Energy’s Section 103 evaluation and DMMP is provided 

in Appendix E. Sampling and analysis of the sediments contained within the proposed dredge area at the 

LNG terminal site was conducted per standard guidelines for assessing dredged materials (EPA and COE 

1991; EPA, Region 4 and COE-SAD 1993; and EPA and COE 1998). 

On January 16, 2006, Bayou Casotte Energy initiated Suitability Testing Phase II based on 

consultations with the COE and EPA. Bayou Casotte Energy submitted the results from the Phase II 

sampling on July 27, 2006, as part of its Joint Permit Application to the COE. It is the responsibility of 

the EPA and COE under the MPRSSA to manage and monitor the ODMDS. The COE has not made its 

final determination on Bayou Casotte Energy’s Section 103 evaluation, and therefore, a final management 

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and monitoring plan has not been prepared for the placement of sediments associated with the Bayou 

Casotte LNG Project. 

4.2.2.1 Physical Characteristics of the Sediments 

The sediments proposed dredged for the marine facilities consist of a sand-rich upper layer and a 

clay- and silt-rich lower layer. On average, there is a 56 percent sand content and a 44 percent silt and 

clay content. The potential for sediments to be resuspended during dredging and dredged material 

placement operations can be estimated from the percentage of silts and clays. The estimated levels of 

total suspended solids (TSS) associated with construction of the proposed Project would be similar to or 

below existing background levels for Bayou Casotte. Section 4.3.2.2 provides additional information on 

methods used and impacts to water quality during dredging and disposal of dredged material. 

Following excavation of soils above the water table at the proposed terminal site, remaining soils 

and sediments (approximately 3.5 mcy) at the proposed terminal slip would be removed using mechanical 

clamshell or dragline dredges mounted on barges. The slip would be dredged to an initial depth of 46 feet 

MLLW, and the sides of the slip would be sloped at a 5:1 ratio, covered with geotextile fabric, and lined 

with protective stone riprap as construction proceeds. It is anticipated that dredging would occur on a 

continuous, 24-hour a day basis, except during brief periods of down time associated with equipment 

maintenance, weather, or other unplanned reasons. The duration of dredging operations is anticipated to 

last for approximately six months. 

Under existing conditions, Bayou Casotte is a turbid estuary. Water quality data collected by 

MDEQ indicated that Bayou Casotte had a median TSS level of 36 mg/l and a mean TSS level of 55 mg/l. 

Bayou Casotte Energy modeled the potential for suspension of sediment associated with dredging of the 

slip using the COE’s DREDGE model. The analysis indicated that maximum predicted levels of TSS 

would be 19.9 mg/l at a distance of approximately 30 feet from the dredging activity, with concentrations 

of TSS dropping at distances further away from the activity. Thus, the estimated levels of TSS associated 

with construction of the proposed Project would be similar to or below existing background levels for 

Bayou Casotte. Furthermore, as a federal navigation project, Bayou Casotte is already routinely subjected 

to periodic COE maintenance dredging and the associated suspension of sediments into the water column. 

Even though the anticipated impacts to marine water resources would be small, Bayou Casotte Energy is 

consulting with MDEQ, MDMR, COE, and NOAA Fisheries regarding the possible development of 

BMPs to further reduce sedimentation and turbidity during construction and maintenance dredging. 

4.2.2.2 Chemical Characteristics of the Sediments 

Metals, nonmetals, PAHs, pesticides, PCBs and TPH were analyzed in all of the sediment 

samples collected from the proposed dredge area. Analytical measurements for each sample were 

compared to sediment quality screening guidelines. Effect range low (ERL) values are defined as the 

lowest chemical concentration in which toxic effects are manifested in selected species (Buchman, 1999). 

All of the analytical results were below ERL values, suggesting no significant impacts would result from 

dredging activities. 

Elutriate chemical testing of the sediments is important in determining whether dredged material 

is suitable for placement at an ODMS by simulating the potential transfer of chemicals from the dredged 

sediments into the water column during dredging activities. Analytical results from elutriate tests were 

compared to Mississippi State and Federal Water Quality Criteria (WQC). No PCBs or pesticides were 

detected above Mississippi State or Federal WQC. With the exception of phosphorous, nickel, and 

mercury; no metals or non-metals were detected above Mississippi State or Federal WQC. Phosphorous 

contained in the elutriate mixture for sample SB10U and nickel contained in the elutriate mixture for 

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sample SB10L were both in excess of the Mississippi State and Federal WQC by an approximate factor of 

two. Mercury contained in the elutriate mixture for SB11U was below the Federal WQC but above the 

Mississippi State WQC by an approximate factor of 16. Since the ODMDS is located in federal waters, 

the analytical results for mercury are in an acceptable range for dredge disposal in federal waters. 

Therefore, dredged material placement at the ODMDS could result in water quality impacts on the 

receiving waters at the site as a result of phosphorus and nickel. We note, however, that elutriate testing 

yields conservative estimates of potential water quality impacts because the tests simulate a greater level 

of sediment mixing and aeration than actually created by mechanical dredging. This is supported by a 

study conducted by the COE to evaluate the release of chemical constituents at the point of dredging, 

which found elutriate test results are a conservative predictor of chemical concentrations within the water 

column (COE 1988). Actual water quality impacts are better evaluated based on biotoxicity and 

bioaccumulation testing as discussed in more detail below. 

4.2.2.3 Biological Testing of the Sediments 

Biological testing was implemented to evaluate any potential effects of open water placement of 

the dredged materials on benthic biota. This testing involved both bioassesment and bioaccumulation 

testing including 10-day whole sediment bioassays using the crustacean Americamysis bahia and the 

crustacean amphipod Leptocheirus plumulosus; 96-hour elutriate bioassays with Americamysis bahia, 

Menidia beryllima, and Arbacia punctylata; and 28-day bioaccumulation tests with Macoma nasuta and 

Nereis verens. The results of each of these stages of toxicity testing are described below. 

Whole-sediment Bioassay Summary 

Dredging activities could potentially affect organisms living and feeding within the sediment 

matrix. To determine the potential for toxicity, and if dredging activities would effect the organisms 

within the sediment matrix, whole sediment bioassays were conducted on sediments collected from the 

dredge area using the crustacean Americamysis bahia and the crustacean amphipod Leptocheirus 

plumulosus. These species were selected to help determine if dredging is anticipated to effect species of 

different feeding strategies. Americamysis bahia is a filter and deposit feeder and L. plumulosus is a 

burrowing filter and deposit feeder. For each species, five replicates were run on a laboratory control 

sediment; a reference sediment; and each of the 14 sediment samples collected from the area proposed for 

dredging. Average percent survival was calculated after 10 days of exposure. Mean percent survival for 

A. bahia in test sediments was not statistically decreased or different by 10 percent when compared to the 

reference sediment. Leptocheirus plumulosus exhibited significant mortality due to exposure to the test 

sediments; however, significant mortality was also observed in the reference sediment. It has been 

demonstrated that without sufficient organic carbon as a food source, organism mortality can occur (Word 

et al. 2005). To determine if the survival rates were attributable to the toxicity of the sediments or the 

lack of a source of adequate nutrients (i.e., organic carbon), three follow-up experimental treatments were 

conducted: 

• Treatment I – Archived site sediments and freshly collected Grand Bay reference sediment 

were tested with a new batch of test organisms. 

• Treatment II – Archived site sediments were conditioned, or “acclimated” to establish a 

marine sediment microbial assemblage. In some cases, samples used for the 28-day 

bioaccumulation test were re-used as it was acknowledged that their conditioning would be 

complete. In other cases, untested archived sediments were conditioned prior to testing. For 

these sediments, ammonia levels were measured during the conditioning process to monitor 

microbial activity. 

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• Treatment III – Previously conditioned sediment was supplemented with TetraMinTM in a 

manner similar to the EPA protocol for the chronic test with the amphipod, L. Plumulosus

(USEPA 2001). The food ration was set at two feedings in 10 days to minimize the amount 

of food in the test system. 

Treatment III toxicity bioassays (i.e., acclimation and TetraMinTM) did not reveal significant 

mortality in any of the 14 test sediments when compared to reference or control sediments. Mean percent 

survival was not statistically decreased or different by 20 percent when compared to the reference 

sediment. The original A. bahia investigation and Treatment III L. plumulosus investigation 

demonstrated that sediments are not toxic to marine organisms and would be considered suitable for open 

ocean placement. 

Elutriate Bioassay Summary 

Elutriate tests were proposed to simulate the conditions that would exist during dredging 

operations. Americamysis bahia, Menidia beryllima, and Arbacia punctylata were tested by exposing 

each species to various concentrations of the 14 different sediment elutriates taken at the proposed dredge 

area for 96 hours. Menidia beryllina did not show significant mortality in any of the elutriate 

concentrations. No toxicity was observed for A. bahia with the exception of one sample (SB7L); 

however, the documented toxicity for that sample was negligible (less than 1 percent). Minor toxicity 

was observed for A. punctulata in two except in samples (SB4U2 and SB7U2); however, it was not 

determined to be significant. The results indicate that there would be no significant mortality among the 

test species and the sediments would comply with the criteria for open ocean placement of dredged 

material. 

Bioaccumulation potential 

Bioaccumulation potential tests were conducted to see if there was a risk of species tissues 

accumulating toxic materials. Sediments were evaluated for heavy metal bioaccumulation potential by 

exposing Macoma nasuta and Nereis verens to material from the proposed dredged area for 28 days. 

After 28-day exposures to the sediments, M. nasuta and N. verens did not demonstrate any toxic effects 

above the control samples. Tissue chemistry data were then compared to FDA action limits for the 

compounds that have established limits. In this case, Mercury is the only compound with established 

limits. Tissue chemistry data for mercury was well below that of the upper confidence limit (UCL) set by 

the FDA. The results indicate that there would be no significant bioaccumulation potential for any of the 

heavy metals detected in the proposed dredged sediments. 

4.3 WATER RESOURCES 

4.3.1 Groundwater 

4.3.1.1 Hydrogeologic Setting 

The proposed Casotte Landing Project is located within the East Gulf Coast Plain Physiographic 

Region, specifically the Coastal Zone, which is a low-lying 5- to 30-mile wide region of slight relief 

(Renken 1998). The regional aquifer underlying the proposed Project is the Coastal Lowlands Aquifer 

System. This aquifer underlies portions of southern Mississippi, Alabama, and Louisiana as well as 

portions of Florida and Texas. The aquifer system extends offshore to the edge of the continental shelf of 

the Gulf of Mexico, but becomes saline in offshore areas. The Coastal Lowlands Aquifer System 

becomes thicker nearer the Gulf of Mexico, is heterogeneous, and generally contains beds of sand, silt, 

and clay. 

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The region overlying the Coastal Lowlands Aquifer System receives ample rainfall, including 

approximately 68 inches annually in southeastern Mississippi (Renken 1998). The Mississippi, Pearl, and 

Red River drainages cross the aquifer system. The groundwater is potable, and is used to supply 

agricultural, public water, domestic, commercial, and industrial wells. In the vicinity of the proposed 

Project, the Coastal Lowlands Aquifer System may occur at approximately 500 feet below sea level 

(Renken 1998). 

According to an environmental site assessment performed for Bayou Casotte Energy in 2005, the 

proposed LNG terminal site is underlain by an upper unconfined, unconsolidated sand unit (Upper Sand 

unit) extending from at or near the ground surface to approximately 23 feet bgs. A lower confined, 

unconsolidated sand unit (Lower Sand unit) occurs below the Upper Sand unit at depths of approximately 

35 to 55 feet bgs. The Upper Clay unit separates the Upper Sand and Lower Sand units. Neither unit is 

used for drinking water. Groundwater flow in the Upper Sand unit is controlled by geology and 

topography and has been affected by past industrial uses at the site. As such, groundwater flow varies at 

the proposed terminal site, with no definitive directional flow for the unit as a whole. Depth to 

groundwater in the Upper Sand unit also is highly variable, with reported depths ranging from 2 to 

20 feet. Groundwater flow in the Lower Sand unit appears to be to the west toward Bayou Casotte. 

4.3.1.2 Public Water Supply and Wells 

Groundwater in the Coastal Lowlands Aquifer System is potable, although depth to freshwater is 

typically deeper than the proposed Project would impact. Two public water supply wells are located 

within a 1-mile radius of the proposed terminal site, but they are located to the north along Bayou Casotte, 

upstream and up-gradient from the proposed Project. No Sole-Source Aquifers, as designated by EPA 

Region IV, are located within the vicinity of the proposed Project. Potable water at the proposed LNG 

terminal would be supplied by an existing well at the Chevron Pascagoula Refinery, and utility water 

would be supplied via municipal mains. 

4.3.1.3 Groundwater Quality 

Screening level samples collected within the area of proposed excavation (defined as 200 feet 

from the edge of the proposed terminal slip) from both the Upper and Lower Sand units contained 

concentrations of constituents that were either above the MDEQ Tier 1 Target Remediation Goals or EPA 

Maximum Contaminant Levels. Constituents detected include several metals and semi-volatile organic 

compounds. These samples were collected as part of the environmental site assessment performed in 

2005. Temporary well points were installed in the Upper Sand unit and permanent wells were installed in 

the Lower Sand unit. Because the samples in the Upper Sand unit were collected from undeveloped 

wells, it is possible that the levels of analytes detected, particularly metals, could have resulted from high 

turbidity. One sample collected from outside of the area proposed for excavation of the new slip 

contained volatile organic compounds and semi-volatile organic compounds at levels exceeding 

regulatory targets. However, this contaminated area, which is located near the west-central boundary of 

the proposed terminal site, appears to be relatively small as other samples collected in the immediate 

vicinity were not contaminated. 

4.3.1.4 Impacts and Mitigation 

Impacts to groundwater resources could result from construction and operations at the proposed 

LNG terminal site, as well as installation of the proposed pipeline interconnects. These potential impacts 

are discussed below. 

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Impacts Associated with Proposed Terminal Construction and Operations 

The Upper and Lower Sand units at the proposed LNG terminal site would be permanently 

affected by construction of the proposed LNG terminal. Site grading, excavation, and dredging activities 

associated with the proposed terminal site and slip would encounter groundwater in the Upper and Lower 

Sand units. Construction and installation of proposed infrastructure, such as sumps and the proposed 

LNG spill impoundment basin, would require dewatering throughout construction activities. The use of 

Bayou Casotte Energy’s Plan and Procedures, as modified in this EIS, would limit impacts associated 

with dewatering. Those measures would include dewatering in a manner that does not cause erosion nor 

result in heavily silt-laden water flowing into any waterbody. Additionally, Bayou Casotte Energy would 

have to comply with any additional measures prescribed by MDEQ in association with the NPDES permit 

that might be granted for the proposed Project. 

As part of the construction of the proposed terminal, existing wetlands and waterbodies would be 

converted to uplands, which would affect recharge for the underlying aquifers, as would the removal of 

vegetation. Since existing vegetation at the proposed terminal site is fragmented, of generally low quality 

(see Section 4.4.1), and part of the terminal site would be re-vegetated after construction, recharge would 

be only temporarily affected in some areas. Permanent effects would occur to groundwater recharge as a 

result from the proposed development of impervious surfaces and structures in some areas of the 

proposed terminal site, but these impacts would be relatively minor overall. 

Chemical analytes, such as volatile and semi-volatile organic compounds and metals have been 

detected at the proposed terminal site in soils and groundwater. Bayou Casotte Energy proposes to 

remove contaminated soils through focused excavations, prior to the start of overall construction, thereby 

preventing chemical mobilization to groundwater or other media. According to the environmental site 

assessment performed for Bayou Casotte Energy, contaminated groundwater was detected at multiple 

locations. Bayou Casotte Energy indicated that if contaminated groundwater was encountered during 

construction or dewatering, that it would be collected in holding tanks or vacuum trucks and disposed of 

offsite in a permitted facility. However, Bayou Casotte Energy has not fully explained how monitoring 

and assessment of groundwater would be achieved during construction or dewatering activities, and 

therefore we recommend that:

• Bayou Casotte Energy develop a plan in consultation with the MDEQ and EPA 

regarding assessment, containment, and disposal of contaminated groundwater that 

might be encountered during any construction activities and file a copy with the 

Secretary prior to the start of construction. 

Pilings for any structures that would impose a significant foundation load (for example, LNG 

storage tanks and vessel berth pilings, etc.) would be driven to depths ranging from 90 to 120 feet bgs. 

These pilings would perforate the clay unit that separates the Upper and Lower Sand units, creating the 

potential for cross-contamination. However, given the limited amount of documented contamination 

onsite, and our recommendation for development of a plan to detect, contain, and remove contaminated 

groundwater during construction, the potential for cross-contamination effects would be low. 

Construction and operation at the proposed terminal site is not expected to result in impacts to 

drinking water wells. The nearest production well is located approximately 0.7 miles north of the 

proposed terminal site. Wells and wellhead protection areas are located up-gradient from the proposed 

terminal site to the north and northeast. Given their distance and location relative to the terminal site and 

plans to prevent mobilization of contaminants to groundwater, impacts to drinking water wells are not 

anticipated. 

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Bayou Casotte Energy has developed a SPCC Plan for the management of hazardous materials, 

such as fuels, lubricants, and coolants that would be used during construction (see Appendix D). 

Measures identified in the SPCC Plan to prevent or minimize the effects of accidental spills during 

construction include provision of adequate primary and secondary containment features, availability of 

spill kits, inspection of drainage from storage areas, and corrosion protection for buried piping. 

Programmatic guidelines in the SPCC Plan include spill reporting, notification of spills to relevant 

agencies, periodic review and evaluation of the plan, inspections, specified hazardous materials storage 

methods, established refueling procedures, and training for both prevention and response. Bayou Casotte 

Energy is also in the process of developing a proposed SPCC Plan to cover the operational phase of the 

proposed Project, and in Section 4.2.1 we have included a recommendation that Bayou Casotte Energy 

finalize and submit that plan prior to the start of construction. 

The proposed Project would include construction of drainage ditches, impoundment basins, and 

sumps for equipment associated with offloading, handling, and storage of LNG at the proposed terminal 

site. These measures would limit the spread and release of LNG that could be inadvertently spilled during 

operations. Any spilled LNG would be covered with high expansion foam, thereby reducing evaporation 

and the potential for ignition. In the unlikely event that LNG is spilled into the water, the cryogenic liquid 

would vaporize rapidly upon contact with the warmer air and water. Being less dense than water, LNG 

would float on the surface prior to vaporizing. Because LNG is not soluble in water and any LNG would 

completely vaporize shortly after being spilled, there would be no liquid left that could mix with and/or 

contaminate the water. Given the measures proposed by Bayou Casotte Energy and our recommendation 

above, we conclude that the potential for effects to groundwater resulting from accidental spills would be 

effectively minimized. 

Although the proposed Project is located near the Gulf of Mexico, saltwater intrusion would not 

be expected to occur as a result of construction and operation of the proposed Project. The regional 

freshwater-saltwater interface at the proposed LNG terminal site is expected to be located at least 120 feet 

below sea level. Additionally, fresh groundwater tends to bulge out under the sea near the coast. As 

dredging at the site would not extend deeper than about 46 feet below MLLW, it is unlikely that saltwater 

intrusion would occur at the site. 

Impacts Associated with Pipeline Interconnects 

Groundwater could be impacted by installation of the proposed pipeline interconnects due to 

open-cut trenching through waterbodies and wetlands, which can affect groundwater recharge, and by 

accidental spills, which are discussed above. As described in Bayou Casotte Energy’s Plan and 

Procedures, as modified in this EIS, measures would be implemented to minimize impacts to wetlands 

during construction. Those measures include use of trench breakers and bottom seals to prevent 

dewatering of wetlands and waterbodies. Trench dewatering would be accomplished so as to avoid 

erosion or discharge of excessively turbid water to any waterbody or wetland, and dewatering structures 

would be removed as soon as possible after the activity is completed. The potential for impacts to 

onshore waterbodies is discussed in greater detail in Section 4.3.2, and wetland impacts are discussed in 

more detail in Section 4.4. Impacts to waterbodies and wetlands that could affect groundwater would also 

be minimized through NPDES and wetlands permit conditions required by MDEQ and the COE, 

respectively. Given that the proposed measures and permit conditions would serve to prevent or 

minimize impacts, we conclude that effects to groundwater resulting from the proposed Project would be 

temporary and minor. 

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4.3.2 Surface Water 

4.3.2.1 Environmental Setting 

As proposed, the Casotte Landing Project would be located on Bayou Casotte, a turbid estuary 

with ambient turbidity levels of approximately 15 to 20 Nephelometric Turbidity Units (NTUs), that 

empties into the Pascagoula Bay/Mississippi Sound portion of the Gulf of Mexico. Bayou Casotte and 

the Gulf of Mexico are the only estuarine or marine waterbodies that would be affected by the proposed 

Casotte Landing Project. The watershed for Bayou Casotte drains approximately 8.4 square miles of 

predominately urbanized and forested area (MDEQ 2002) and is located in the Mississippi Coastal 

Streams River Basin. Bayou Casotte is approximately 1,100 feet wide with a depth of up to 42 feet, 

which is controlled by routine dredging to maintain an actively used shipping channel. The proposed 

Project would be located within a previously altered and existing industrialized area along Bayou Casotte. 

The State of Mississippi assigned Bayou Casotte a state fishery classification of “marine” and a 

designated use of “fish and wildlife.” There are no officially designated recreational, commercial, or 

shellfish resources in Bayou Casotte, although some private recreational fishing does occur there and the 

area is a launching and access point for chartered fishing boats. Designated critical habitat for the 

federally threatened Gulf sturgeon (Unit 8, Mississippi Sound in Jackson County, Mississippi) is located 

at and immediately adjacent to the southwest corner of the proposed LNG terminal site. Gulf sturgeon 

habitat is discussed in more detail in Section 4.6. Bayou Casotte is listed as an impaired waterbody 

(impaired aquatic life support) by the MDEQ due to the presence of total toxics and unionized ammonia 

(MDEQ 2005). 

Numerous cold fronts, in addition to more rare tropical cyclones, occur each year and affect wind 

and wave patterns in the vicinity of the proposed Project (Keen et al. 2003). Winds in the vicinity of 

Bayou Casotte tend to focus wave energy from the southwest toward the northeast, with the potential to 

cause shoreline erosion and mobilize sediments. Keen et al. (2003) indicated that the wave climate in 

Mississippi Sound was generally moderate, with wave heights typically less than 3 feet, and also 

suggested that currents in Mississippi Sound were dominated by tidal flow. The average difference in 

range of tides at Pascagoula, Mississippi is 1.5 feet (USM 2005). Coastal Mississippi is subject to 

impacts from major hurricanes that affect rainfall, wind, waves, and tides, as evidenced by the landfall of 

Hurricane Katrina near the Louisiana and Mississippi border on August 29, 2005 (Knabb et al. 2005). 

Hurricane Katrina made landfall as a strong Category 3 storm with winds exceeding 110 miles per hour 

and a storm surge of up to 27 feet (Knabb et al. 2005) after weakening from a Category 5 storm while in 

the Gulf of Mexico. 

The onshore waterbodies that would be affected by the proposed Project range from freshwater to 

brackish in character, and additional information regarding their characteristics is provided in 

Table 4.3.2-1. Construction of the proposed terminal site would affect 14 onshore surface waterbodies, 

comprised of 10 ditches, two ponds, and two canals. The terminal site is located in an existing industrial 

area, and the site previously contained a refractory brick manufacturing plant that was closed and 

remediated in 1989. Two canals would be affected by construction of the proposed pipeline 

interconnects. Additionally, the nonjurisdictional NGL pipeline would affect five perennial ditches and 

one perennial canal. 

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TABLE 4.3.2-1 

Onshore Waterbodies Affected by the Proposed Casotte Landing Project 

Feature ID / Facility Description Type Bank Width 

(feet) 

Water Width 

(feet) 

Water Depth 

(feet) 

S1AJA001/Terminal Ditch Intermittent 4 1 1.0 

S1AJA002/Terminal Canal Perennial 40 40 2.0 

S1AJA003/Terminal Canal Perennial 60 40 2.0 

S1AJA004/Terminal Pond (2.5 acre) Perennial 440 430 4.0 

S1AJA005/Terminal Ditch Perennial 20 8 0.5 

S1AJA006/Terminal Pond (0.1 acre) Perennial 50 40 4.0 

S1AJA007/Terminal Ditch Perennial 20 10 2.0 

S1AJA008/Terminal Ditch Intermittent 20 10 0.5 

S1AJA009/Terminal Ditch Intermittent 15 4 0.5 

S1AJA010/Terminal Ditch Perennial varied varied 1.5 

S1AJA011/Terminal Ditch Intermittent 25 8 1.0 

S1AJA012/Terminal Ditch Intermittent 30 8 1.0 

S1AJA013/Terminal Ditch Intermittent 40 6 1.0 

S1AJA014/Interconnects Canal Perennial 45 12 0.5 

S1AJA015/Terminal Ditch Intermittent 15 6 1.0 

S1AJA015/NGL Ditch Perennial 15 15 1.5 

S1AJA016/NGL Ditch Perennial 15 15 1.5 

S1AJA017/NGL Ditch Perennial 15 15 1.5 

S1AJA018/NGL Ditch Perennial 15 15 1.5 

S1AJA019/NGL Ditch Perennial 15 15 1.5 

S1AJA020/NGL Canal Perennial 70 40 1.5 

S1AJA021/Interconnects Canal Perennial 85 60 4.0 

Virtually all of the onshore waterbodies that would be affected by the proposed Project are 

artificially constructed canals, ditches, or ponds. Bayou Casotte Energy qualitatively characterized all of 

the affected onshore waterbodies as of “low quality,” indicating that there were significant disturbances 

associated with the channels and riparian areas and that available aquatic habitat was marginal or 

generally unsuitable. All of the waterbodies have sandy substrates, carry a “warmwater” State fisheries 

designation, and have a designated use of “fish and wildlife.” None of the onshore waterbodies are 

designated as sensitive resources or as sources for public surface water intakes. 

4.3.2.2 Impact and Mitigation 

Construction 

The proposed Project could affect the quality of surface water resources in the proposed Project 

vicinity in several ways. Potential impacts to surface waters related to construction include runoff from 

the terminal site during excavation and construction, sedimentation, turbidity, accidental spills, and 

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possible mobilization of contaminants associated with dredging of the terminal’s slip. Marine water 

quality in the Gulf of Mexico could also potentially be affected by the proposed disposal of dredged 

sediments at the Pascagoula Ocean Dredged Material Disposal Site (ODMDS), which is located 

approximately 11 nautical miles offshore. Hydrostatic testing of the LNG storage tanks and pipeline 

interconnects could also result in potential effects, which are discussed below. 

Impacts Associated with Terminal Construction Excavation

The proposed Project would involve the excavation and removal of approximately 1.0 mcy of soil 

located at or above the water table from the proposed terminal slip. The excavation would be 

accomplished with standard earthmoving equipment and the excavated material would be stockpiled onsite and used for fill, leveling, and construction of the proposed LNG terminal. 

Impacts to the 14 onshore waterbodies associated with the proposed terminal site would be 

permanent. All onshore waterbodies at the terminal site would be filled, graded, or otherwise altered 

during site preparation and excavation, and each would be permanently converted to uplands. However, 

given that the onshore waterbodies at the proposed terminal site are located in a previously disturbed, 

heavily impacted industrial area, are wholly man-made, and are of low quality, we conclude that 

construction of the proposed LNG terminal would not result in a significant adverse effect to surface 

freshwater resources. Rather, existing drainage patterns including artificial onshore waterbodies that were 

created and modified to meet the needs of past industrial development would be altered to meet the needs 

of the proposed industrial development. Drainage at the proposed terminal site following construction 

would be controlled during operations through a new stormwater management system, as discussed 

below. Mitigation for permanent impacts to existing onshore waterbodies at the terminal site may be 

required as part of the permitting required by agencies including the COE, MDMR, and MDEQ. 

Runoff 

Runoff from the terminal site to Bayou Casotte during construction would be controlled and 

minimized through implementation of Bayou Casotte Energy’s Plan, as modified in this EIS (see below), 

which includes installation of temporary and permanent erosion control measures such as silt fencing, 

straw bales, slope breakers, sediment barriers, mulch, trench breakers, re-vegetation, daily inspection of 

cleared areas, and monitoring and maintenance of previously disturbed areas. Additionally, and as a 

requirement of the general permit for construction stormwater discharge that might be issued by the 

MDEQ, Bayou Casotte Energy has developed a site-specific SWPPP that details the BMPs to be used 

during construction (see Appendix C). 

Dredging 

Following excavation of soils above the water table at the terminal site, remaining soils and 

sediments (approximately 3.5 mcy) at the proposed terminal slip would be removed using mechanical 

clamshell or dragline dredges mounted on barges. The slip would be dredged to an initial depth of 46 feet 

MLLW, and the sides of the slip would be sloped at a 5:1 ratio, covered with geotextile fabric, and lined 

with protective stone riprap as construction proceeds. It is anticipated that dredging would occur on a 

continuous, 24-hour a day basis, except during brief periods of down time associated with equipment 

maintenance, weather, or other unplanned reasons. Dredging operations would last for approximately six 

months. 

Under existing conditions, Bayou Casotte is a turbid estuary. Water quality data collected by 

MDEQ indicated that Bayou Casotte had a median TSS level of 36 mg/l and a mean TSS level of 55 mg/l. 

Bayou Casotte Energy modeled the potential for suspension of sediment associated with dredging of the 

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slip using the COE’s DREDGE model. The analysis indicated that maximum predicted levels of total 

suspended solids (TSS) would be 19.9 mg/l at a distance of approximately 30 feet from the dredging 

activity, with concentrations of TSS dropping at distances further away from the activity. Thus, the 

estimated levels of TSS associated with construction of the proposed Project would be similar to or below 

existing background levels for Bayou Casotte. Furthermore, as a federal navigation project, Bayou 

Casotte is already routinely subjected to periodic COE maintenance dredging and the associated 

suspension of sediments into the water column. Even though the anticipated impacts to marine water 

resources would be small, Bayou Casotte Energy is consulting with MDEQ, MDMR, COE, and NOAA 

Fisheries regarding the possible development of BMPs to further reduce sedimentation and turbidity 

during construction and maintenance dredging. In addition, Bayou Casotte Energy would be required to 

conduct water quality monitoring as a condition of its Section 401 Water Quality Certification. Based on 

the results of water quality monitoring, Bayou Casotte Energy could adjust the rate of dredging to reduce 

impacts resulting from elevated TSS levels. Based on the existing TSS levels and the implementation of 

Bayou Casotte Energy’s mitigation measures, as well as those developed in consultation with the 

applicable agencies, we believe that potential impacts on water quality associated with the proposed 

dredging activities would be sufficiently minimized. 

Disposal of Dredged Material 

Bayou Casotte Energy has developed a DMMP that describes the dredging and material 

placement operations that would be needed for construction and operation of the proposed Project. In the 

DMMP, Bayou Casotte Energy proposes to place sediments dredged from the terminal slip into bottom 

dump scows for disposal at the EPA’s permitted Pascagoula ODMDS, which is located in the Gulf of 

Mexico south of Horn Island. Assuming an average scow capacity of approximately 3,000 yd3

 and Bayou 

Casotte Energy’s estimate that up to 10 scow loads per day would place dredged spoils at the Pascagoula 

ODMDS, it would take approximately six months to complete dredging operations. 

Bayou Casotte Energy developed an agency-approved plan to test sediments prior to final 

selection of disposal methods and sites. Results of this plan were submitted to the COE on July 27, 2006 

as part of Bayou Casotte Energy’s Joint Permit (see Section 4.2.2 and Appendix E). Furthermore, and if 

approved for use, Bayou Casotte Energy would perform a bathymetry survey of the ODMDS following 

disposal, and EPA would conduct sediment mapping. 

The Pascagoula ODMDS routinely accepts spoils from Bayou Casotte, and the site was designed 

for use by multiple entities, including the adjacent Chevron Pascagoula Refinery (EPA 1991). The 

disposal of dredged sediments at the ODMDS was evaluated in an EIS prepared by the EPA (1991), in 

coordination with the U.S. Navy and COE as cooperating agencies. At that time, the COE required a 

disposal site for spoils resulting from maintenance dredging within the federal shipping channel extending 

from the Gulf of Mexico to Mississippi Sound, the Pascagoula River, and Bayou Casotte. The EPA 

concluded that impacts associated with placement of the dredged materials in the ODMDS would be 

localized to the vicinity of the disposal site and that they “would not significantly alter the long-term 

productivity of the site.” 

For the reasons outlined above, we do not anticipate that disposal of sediments excavated from 

the proposed LNG terminal slip would result in significant adverse effects to marine surface waters. The 

Commission and Bayou Casotte Energy are proceeding under the assumption that sediments would be 

suitable for placement in the ODMDS. However, the final agency approvals required pursuant to 

Section 103 of the MPRSA have not yet been obtained (see Section 4.2.2). 

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Waterbody Crossings Associated with Pipeline Facilities

Bayou Casotte Energy proposes to use open-cut construction techniques to cross all of the 

affected waterbodies during installation of the proposed pipeline interconnects and the nonjurisdictional 

NGL pipeline. In order to minimize potential environmental impacts, the NGL pipeline would be 

completely collocated with the proposed interconnect spur, the existing Gulfstream pipeline, and the 

existing MPC electric transmission line right-of-way. 

The greatest potential impact of the open-cut construction method on surface waters would be 

turbidity and sedimentation caused by instream construction or by erosion of cleared waterbody banks. 

The FWS also commented that it was concerned that open-cut trenching might lead to head cutting that 

could result in bank sloughing and channel erosion. The extent of the impact would depend on existing 

sediment loads, stream velocity, turbulence, waterbody bank composition, sediment particle size, and the 

extent of the disturbance to the channel. To minimize the potential for impacts to water quality, open-cut 

crossings would be accomplished in accordance with Bayou Casotte Energy’s Procedures, as modified in 

this EIS (see below), which include measures to: (1) limit clearing of vegetation adjacent to waterbodies, 

(2) maintain adequate flow rates, (3) install equipment bridges, (4) complete instream construction 

activities, including restoration of the streambed contours, within 48 hours, (5) install and maintain 

sediment barriers, (6) stabilize waterbody banks within 24 hours of completion of instream construction, 

and (7) revegetate disturbed riparian areas. Given the anticipated rapid restoration of the streambed 

contours and the relatively flat topography and channel gradients in the area, we do not anticipate that 

head cutting in waterbodies crossed by the proposed pipeline interconnects would be likely to occur or 

result in significant impacts. Additionally, Bayou Casotte Energy would comply with any waterbody 

permit and mitigation requirements specified by the COE, MDMR, and MDEQ. Given the relative low 

quality of the onshore waterbodies crossed by the proposed pipeline interconnects and NGL pipeline, as 

well as required measures to prevent or minimize impacts, we conclude that the crossings would not 

result in more than a temporary adverse effect to fresh water resources. 

Bayou Casotte Energy’s Proposed Variances to the FERC's Procedures 

In response to past concerns raised by federal, state, and local agencies, the FERC developed 

Procedures to provide a baseline level of protection for surface waterbodies and wetlands crossed during 

pipeline construction. The FERC's Procedures include requirements for pre-construction planning, 

environmental inspection, specific construction methods, sediment and erosion control, restoration, and 

post-construction maintenance. Bayou Casotte Energy has requested certain variances from the FERC's 

standard Procedures. In the case of construction activities at the terminal site, waterbodies and wetlands 

would not simply be crossed and then restored, rather they would be filled, graded, or otherwise 

completely removed. Because of the large-scale, permanent modification of the proposed terminal site, 

we recognize that certain construction activities would be required within, and immediately adjacent to, 

existing waterbodies and wetlands. Due to this feature of the proposed Project, some of the standard 

measures in the FERC's Procedures would not be applicable at the proposed LNG terminal site including: 

• restriction of extra workspace within 50 feet of a waterbody or wetland (Sections V.B.2.a, 

V.B.2.b, VI.B.1.a, VI.B.1.b); 

• marking of waterbody and wetland boundaries and buffers (Sections V.B.3.f, VI.A.4); 

• restriction of placement of spoil within 10 feet of the water’s edge (Sections V.B.4.a); and 

• limitation of vegetation maintenance along waterbodies to allow a riparian strip 25 feet wide 

(Section V.D.1). 

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The FERC's acceptance of these requested variances applies only to the proposed LNG terminal 

site. Other areas that would be affected by construction of the proposed pipeline interconnects must 

comply with the FERC's standard Procedures, regardless of whether access is obtained via easement 

agreement. 

Additionally, Bayou Casotte Energy proposed several variances that are relatively minor 

modifications, reflect consideration of site conditions, and that offer similar levels of environmental 

protection as provided by the FERC's Procedures. Those measures, which are approved, include: 

• use of salvaged flat bed rail cars or equivalent in addition to flexi-float or portable bridges 

(Section V.B.5.b) ; 

• that sediment barriers would allow for ingress and egress to any equipment bridges present 

(Section V.B.10.a); and 

• use of flexible channel liners in addition to seeding and erosion control fabric as vegetative 

stabilization techniques (Section V.C.5). 

Any proposed expansion of the construction right-of-way associated with waterbodies or 

wetlands must be approved in writing by the Commission on a site-specific basis prior to construction. 

Although the FERC would consider site-specific requests for a variance based on conditions that may be 

encountered during construction, the FERC does not expect that this variance would be required for all 

wetland crossings. Additionally, Bayou Casotte Energy proposed numerous other variances from the 

FERC's Procedures that either were not sufficiently supported or did not offer similar levels of 

environmental protection. These other proposed variances have been rejected. 

Therefore, we recommend that: 

• Except for the proposed variances specifically approved above, Bayou Casotte Energy 

should revise its proposed Procedures to be consistent with the FERC's standard 

Procedures, as modified in this EIS. The revised Procedures should be filed with the 

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

Hydrostatic Testing

Bayou Casotte Energy would perform a hydrostatic test for structural integrity of the LNG 

transfer lines, storage tanks, and all pipelines prior to operation. The hydrostatic testing would be 

conducted in accordance with the DOT’s specifications (49 CFR 192). Pending completion of water 

suitability and compatibility analyses and MEDQ approval, Bayou Casotte Energy proposes to withdraw 

approximately 28 million gallons of test water at a rate of approximately 264,000 gallons per hour from 

Bayou Casotte. Test water would be sequentially re-used for hydrostatic testing of each LNG storage 

tank, being transferred through the LNG transfer lines to each of the three tanks, thereby minimizing 

water withdrawals to the extent possible. The same test water, albeit a smaller amount (approximately 

450,000 gallons) would also be re-used for hydrostatic testing of the pipeline interconnects. Additionally, 

it is anticipated that a separate 135,000 gallons of test water would be used to test the nonjurisdictional 

NGL pipeline. 

Following completion of hydrostatic testing, the water would be analyzed to determine whether 

treatment is required prior to discharge. Treatment measures could include filtration, oil/water separation, 

clarification, carbon adsorption, and chemical injection. After determination that the water is suitable for 

discharge or sufficiently treated, it would then be discharged back to Bayou Casotte at the completed 

terminal slip at a rate of approximately 60,000 to 120,000 gallons per hour. To prevent erosion, energy 

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dissipation devices and erosion control techniques such as hay bales and silt fencing would be used 

during discharge of hydrostatic test water. Bayou Casotte Energy anticipates hydrostatic testing for the 

LNG tanks and pipeline interconnects would take approximately 16 and two weeks to complete, 

respectively. Given its anticipated schedule, Bayou Casotte Energy estimates that hydrostatic testing 

would occur in the spring or summer seasons. 

If required as a result of suitability analyses that would be performed prior to the start of 

hydrostatic testing, additives could be combined with the hydrostatic test water. These additives could 

include biocides that prevent corrosion caused by bacteria, other corrosion inhibitors, oxygen scavengers, 

and leak detection tracers. All of the potential additives except leak detection tracers are considered 

potentially toxic in the aquatic environment. Bayou Casotte Energy is in the process of consulting with 

MDEQ regarding the hydrostatic test water and the use of such additives, should they become necessary. 

To minimize the potential for impacts to water quality from hydrostatic testing, we recommend that: 

• Bayou Casotte Energy submit the results of consultations with MDEQ regarding the use 

of hydrostatic test water additives to the Commission prior to the start of construction, 

and not use corrosion inhibitors, biocides, oxygen scavengers, or other hydrostatic test 

water additives that exhibit toxicity to aquatic organisms without prior written 

approval by the Director of OEP. 

Bayou Casotte Energy has proposed several measures to minimize impacts to water quality 

resulting from hydrostatic testing. These measures include: 

• withdrawal from and discharge to water sources in compliance with agency requirements in 

consideration of the protection of fishery resources on a case-by-case basis; 

• compliance with all permit requirements; and 

• screening of intakes to avoid entrainment and impingement of fish and other aquatic 

organisms. 

Additional discussion regarding hydrostatic testing and potential effects to fishery resources is 

included in Section 4.5. Given the proposed minimization of water withdrawals to the extent possible, 

Bayou Casotte Energy’s measures to prevent or minimize impacts, ongoing consultations with MDEQ 

and NOAA Fisheries that may result in additional protective measures, and the FERC's recommendation 

regarding the use of hydrostatic test water additives, we conclude that hydrostatic testing of the proposed 

Project would not result in more than a temporary adverse effect to water resources. 

Mobilization of Contaminants

Potentially contaminated soils and sediments at the terminal site have been largely identified and 

delineated during previous environmental site assessments. These contaminated sediments are located at 

or near the ground surface and they would be removed by focused excavation activities prior to the start 

of generalized excavation or dredging at the terminal site. Additionally, the suitability of the dredged 

material from the proposed terminal slip for placement at the ODMDS has not yet been approved by the 

COE and EPA. All contaminated soils and sediments would be properly disposed of off-site at permitted 

landfills in compliance with EPA’s guidelines and solid waste management procedures 

(40 CFR 260-265). Given that contaminated soils and sediments have been delineated and would be 

removed through focused excavations prior to the start of general excavation and dredging, the risk of 

mobilization of contaminants to Bayou Casotte or other areas is small. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Accidental Spills

Surface waters could potentially be impacted from the inadvertent release of fuel, oil, or other 

hazardous fluids during transfer (e.g., refueling) or storage of these materials near surface waterbodies. 

Water quality in the vicinity of the spill would be impaired and acute, and chronic toxic effects to aquatic 

organisms could occur. Impacts from fuel spills would be avoided or minimized through implementation 

of guidelines presented in Bayou Casotte Energy's Plan and Procedures, as modified in this EIS, and 

Bayou Casotte Energy’s SPCC Plan. As discussed in Sections 4.2.1 and 4.3.1, Bayou Casotte Energy has 

developed a SPCC Plan for construction activities (see Appendix D). In Section 4.2.1 we have 

recommended that Bayou Casotte Energy submit an operational SPCC Plan prior to the start of 

construction. 

Operation 

Potential impacts related to operation of the proposed Project include stormwater runoff; 

accidental spills; bank erosion caused by waves or vessel propeller wash; intake and discharge of ballast 

water and cooling water by LNG marine traffic and other vessels visiting the terminal; effects of the 

terminal slip on water quality; and maintenance dredging. Because the primary LNG vaporization system 

would operate in a closed loop using waste heat from the Chevron Pascagoula Refinery, significant 

volumes of cooled waters would not be discharged as a result of operation of the proposed Project. 

Stormwater Runoff

Storm water at the proposed terminal site would be routed by surface ditches and swales adjacent 

to roads and the hurricane levee before collection in catch basins. Storm water collected inside of the 

hurricane levee would be pumped over the levee to the storm sewer systems outside of the levee. Areas 

subject to spills of oil and lubricants would be drained to a separate collection area and oil separator. 

Recovered oil would be transported off-site for recycling or disposal and treated oily water would be 

pumped to the sanitary system for treatment and disposal. Curbed areas would be used to contain spills 

and prevent contamination of storm water. Storm water would collect in four basins and would ultimately 

be discharged via two new outfalls into Bayou Casotte. Bayou Casotte Energy would employ general 

BMPs including good housekeeping, preventative maintenance, visual inspections, spill prevention and 

response, and management of runoff. The specific measures that would be implemented by Bayou 

Casotte Energy during operations would be identified in an Industrial SWPPP, which would be required 

to comply with the provisions of a NPDES Industrial Stormwater Permit, if issued by MDEQ. In 

Section 4.2.1, we have included a recommendation for Bayou Casotte Energy to finalize the Industrial 

SWPPP in consultation with MDEQ prior to the start of construction. 

Accidental Spills

Measures to prevent or minimize the effects of accidental spills, including spills of LNG, during 

construction are discussed in Sections 4.2.1 and 4.3.1. Additionally, in Section 4.2.1, we have included a 

recommendation that Bayou Casotte Energy develop and finalize an operational SPCC Plan prior to the 

start of construction. The measures identified in the operational SPCC Plan would prevent or minimize 

the effects of any accidental spills during operation. 

The LNG terminal was designed to account for an accidental spill of LNG during operation of the 

facility and to prevent any LNG from entering Bayou Casotte. In the unlikely event that LNG is spilled 

into the water either from the LNG terminal itself or from an LNG carrier during transit to the LNG 

terminal, the cryogenic liquid would vaporize rapidly upon contact with the warm air and water. Being 

less dense than water, LNG would float on the surface prior to vaporizing. Because LNG is not soluble in 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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water and would completely vaporize shortly after being spilled, the LNG could not mix with or 

contaminate the water. Additional information on the environmental impacts resulting from LNG ships 

and transit is provided in Section 4.12.5.3. 

Bank Erosion 

Bank erosion could reduce bank stability and result in increased turbidity and suspended 

sediments in Bayou Casotte and adjacent areas. However, it does not appear that the location, size, and 

shape of the proposed terminal slip would result in significantly modified flow velocities or wave action 

that could promote increased erosion of the channel banks. The proposed slip would have only very 

localized effects on velocities and the area proposed for dredging is small compared to the much larger 

open-water area where waves develop. Additionally, the movement of large vessels, such as LNG 

carriers or crude oil tankers, has the potential to result in bank erosion and associated turbidity through 

creation of waves or wakes caused by propeller wash. However, the proposed terminal site is located 

near the downstream end of an existing shipping channel and erosion within the proposed slip would be 

limited by the use of rock riprap overlaid on a geotextile fabric. Bank erosion could occur as a result of 

the LNG vessel passage between Petit Bois and Horn Islands, and when vessels operate near and/or at the 

facility’s berthing area. Because of the anticipated speed of the LNG vessels transiting the waterway and 

the distance from Petit Bois and Horn Islands to the transit channel, bank erosion would not be 

significant. Given these factors, potential effects to water quality from bank erosion would be small. 

Intake of Ballast Water and Cooling Water by LNG Carriers

LNG carriers would take on ballast water to maintain stability and use seawater to cool engines 

during offloading of LNG at the proposed terminal. These activities have the potential to use large 

quantities of water from Bayou Casotte. A single LNG carrier could take on approximately 15 million 

gallons of ballast water during each offloading operation, and given that approximately 170 vessels may 

visit the proposed terminal each year, up to 2.5 billion gallons of ballast water could be withdrawn from 

Bayou Casotte on an annual basis. Additionally, LNG carriers use seawater to cool their engines during 

LNG offloading operations. This process could use approximately 15 to 42 million gallons of seawater 

per offloading event (depending on whether the carrier is steam or electric powered), and could result in 

the use of approximately 4.8 billion gallons of seawater on an average annual basis. 

Given the location of the proposed terminal site near the mouth of Bayou Casotte, adjacent to 

Mississippi Sound and the Gulf of Mexico, sufficient water is available to provide the quantities 

necessary for ballast and engine cooling operations. Because the LNG ships would be fully loaded with 

LNG when transiting to and arriving at the proposed terminal, no ballast water would be discharged along 

the waterway in the Mississippi Sound. It is anticipated that ballast water would be taken on and retained 

during LNG offloading operations and no ballast water would be discharged in Bayou Casotte. There is 

potential for harm to the marine environment through introduction of exotic and invasive marine 

organisms from ballast operations, and these potential impacts are discussed in Section 4.5.2. 

Additionally, the transited waterway is an active commercial shipping channel already subject to the 

withdrawal and discharge of vessel engine cooling water, and that activity would not substantially affect 

water quality in the proposed Project area. Furthermore, heavy shipping traffic augments the mixing and 

circulation of water in the waterway, thus reducing impacts from ballast water and cooling water intake. 

Effects of Slip Creation on Water Quality

Impacts could occur to water quality within the proposed terminal slip and adjacent Bayou 

Casotte due to the recessed nature of the slip and the potential for stagnation. However, the potential for 

these impacts would be eliminated or effectively minimized through tidal flushing and regular LNG 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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carrier, crude oil tanker, and tug traffic. Also, the generally shallow nature of the slip would reduce the 

potential for adverse impacts. However, Bayou Casotte Energy is in the process of consulting further 

with MDMR and MDEQ regarding the proposed slip and potential effects on water quality, and therefore 

we recommend that:

• Bayou Casotte Energy complete consultations with MDMR and MDEQ regarding 

potential impacts to water quality within or adjacent to the proposed terminal slip and 

file a report documenting the findings of those consultations and any required 

mitigation or monitoring measures with the Secretary prior to the start of construction. 

Maintenance Dredging 

According to preliminary modeling, Bayou Casotte Energy estimates that maintenance dredging 

of the proposed terminal slip could generate up to about 250,000 yd3

 of material per year during 

operations, as described in Section 2.7.1. In the DMMP, Bayou Casotte Energy has identified placement 

of maintenance dredge materials at the Pascagoula ODMDS as its primary disposal option. Bayou 

Casotte Energy has also indicated that it would consider placement of maintenance dredge materials at 

beneficial use sites, as well as coordination of maintenance dredging with the COE’s routine maintenance 

dredging of the Bayou Casotte channel. 

As discussed previously in relation to initial dredging associated with construction of the 

proposed terminal slip, Bayou Casotte is an industrialized shipping channel that is already subject to 

routine maintenance dredging by the COE. Additionally, Bayou Casotte Energy is in the process of 

consulting with MDEQ, MDMR, COE, and NOAA Fisheries regarding the development of dredging 

BMPs and possible monitoring measures. Furthermore, Bayou Casotte Energy has filed its dredge 

material suitability testing results and evaluations pursuant to Section 103 of the MPRSA (see 

Appendix E). Final approvals from EPA and COE regarding selection of the Pascagoula ODMDS as the 

dredge material placement site have not been made. With implementation of the measures and 

recommendations, it is not anticipated that maintenance dredging would result in significant effects to 

marine surface waters, especially given the existing turbid nature of Bayou Casotte. 

4.4 VEGETATION AND WETLANDS 

4.4.1 Habitat/Community Types 

The Casotte Landing LNG Project is located in a coastal setting comprised of the marine 

environment of the waterway and berthing facility transitioning to estuarine and upland communities 

farther inland. Dominant vegetation types of the proposed Project were identified during field evaluations 

performed by the Bayou Casotte Energy in April 2005 and December 2005. Hurricane Katrina is likely to 

have had a short-term impact on upland vegetation communities in the Project area. Salt stress associated 

with the storm surge may have resulted in temporary die-off of some plant species, but not to the extent 

that the communities mapped and characterized prior to the hurricane are invalid. Additionally, some of 

the field evaluations performed for the proposed Project were conducted following the hurricane. 

Vegetation in the Project area includes upland and wetland communities as described below. 

Two general categories of upland vegetation were identified: commercial/industrial associated vegetation 

and right-of-way associated vegetation. Wetlands identified by Bayou Casotte Energy were classified as 

palustrine emergent, palustrine scrub-shrub, palustrine forested, estuarine emergent, or estuarine scrubshrub. The wetland communities potentially affected by the Project are discussed in Section 4.4.3. 

Submerged aquatic vegetation does not occur in the immediate vicinity of the proposed Casotte Landing 

Project. The nearest submerged aquatic vegetation community is located approximately 4 miles east of 

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the proposed terminal site. The LNG marine traffic, however, would transit confined areas between the 

barrier islands and the mainland, where submerged aquatic vegetation could be present. Beach dunes also 

exist on Petit Bois and Horn Islands along the LNG ship transit route. 

Submerged aquatic vegetation, or seagrass, occurs in relatively shallow coastal waters of the 

Mississippi Sound as a result of depth-limited penetration of sunlight associated with the relatively turbid 

waters of the coast. Seagrass occurs in open waters from 1 to 9 feet deep, typically in a sandy substrate 

with various amounts of shells and shell fragments (MDMR 1998a). Seagrass beds commonly consist of 

turtle grass (Thalassia testudinum), shoal grass (Halodule wrightii), and manatee grass (Syringodium 

filiforme). Submerged vegetation near the mainland is dominated by two species; widgeon grass (Ruppia 

maritime) and to a lesser extent tape grass (Vallisneria americana). 

The beach dune community on both Petit Bois and Horn Islands consists of two distinct plant 

associations. The hardy pioneer plants colonize the foredune and are dominated by sea oats, which are 

able to survive both partial burial by sand and exposure of the root system when sand is blown away. The 

extensive root system of this plant aids in dune stabilization. On the protected lee side of the dune a large 

variety of plants occur, including beach grass, bunch grass, prickly-pear cactus, and golden aster 

(National Park Service 2006). 

4.4.1.1 LNG Terminal Facilities 

The terminal site is a heavily disturbed and previously developed area within an industrial port 

setting. The commercial/industrial associated vegetation present at the site is representative of this 

disturbance, and is generally sparse, fragmented and of low quality. About 115 acres of 

commercial/industrial land-associated vegetation would be impacted by the construction of the proposed 

terminal. No upland forested areas occur at the proposed terminal site. Field surveys found that the 

commercial/industrial associated vegetation at the terminal site was dominated by herbaceous species 

such as blackberry (Rubus argutus), dogfennel (Eupatorium capillifolium), broomsedge (Andropogon 

virginicus), and invasive, exotic species, which are discussed further below. 

Following construction, the entire terminal site would be permanently converted to industrial use. 

Although operation of the proposed LNG terminal facilities would permanently remove native vegetation, 

these impacts are not expected to be significant on a regional scale because areas with similar vegetation 

characteristics are common in surrounding areas. Additional information on the environmental impacts 

resulting from the transit of the LNG ships is provided in Section 4.12.5.3. 

Additional impacts on vegetation could occur as a result of construction and operation of the 

nonjurisdictional electrical transmission facilities associated with the LNG terminal. However, the final 

route for these facilities has not been determined. 

4.4.1.2 Interconnect Pipeline and Associated Aboveground Facilities 

The proposed interconnect pipeline would traverse existing rights-of-way along Ranson Road and 

West Hardee Road. The nonjurisdictional NGL pipeline and the pipelines associated with the 

nonjurisdictional water circulation system would traverse areas of upland vegetation associated with the 

Chevron Pascagoula Refinery perimeter. The upland vegetation associated with these areas is similar in 

composition to that identified at the proposed terminal site and is frequently disturbed by routine 

maintenance activities. No upland forested areas occur along the proposed pipeline interconnect route. 

Construction of the proposed interconnect pipeline would temporarily affect 2.1 acres of upland 

herbaceous vegetation associated with existing rights-of-way. The proposed nonjurisdictional NGL 

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pipeline and circulation water system would affect 16 and 7.9 acres, respectively, of similar 

commercial/industrial land associated vegetation. 

During construction, existing vegetation including herbaceous and shrub species would be 

temporarily removed from within the pipeline construction right-of-way and other workspaces as 

necessary. The impacts of clearing vegetation generally include the loss of habitat, habitat fragmentation, 

increased absorption of solar radiation into affected soils, and a greater potential for surface water 

movement/erosion. 

To minimize impacts on vegetation, Bayou Casotte Energy has routed the proposed interconnect 

pipeline and nonjurisdictional facilities so that they would be collocated with existing facilities to the 

maximum extent possible. Additionally, Bayou Casotte Energy would restore the construction right-ofway in accordance with its Plan and Procedures, as modified in this EIS. Implementation of the measures 

provided in its modified Plan and Procedures would minimize potential long-term impacts on vegetation 

by allowing annual maintenance of only a 10-foot-wide strip centered over the pipeline. Additionally, 

routine vegetation maintenance across the entire permanent right-of-way could occur only once every 

three years in uplands and would be restricted in wetlands to the periodic clearing of trees greater than 

15 feet in height that are within 15 feet of the pipeline centerline. Therefore, we believe that impacts 

resulting from construction and operation of the proposed pipeline and aboveground facilities would not 

significantly affect vegetative resources. 

4.4.2 Invasive Plant Species 

Upland areas at the proposed terminal site and along the proposed pipeline interconnects provide 

habitat conducive to the propagation of invasive exotic weeds and nuisance vegetation. Invasive plant 

species observed during field surveys of the terminal site and along the proposed pipeline routes include 

Chinese tallow (Sapium sebiferum), Chinese privet (Ligustrum sinense), cogongrass (Imperata 

cylindrica), and Japanese honeysuckle (Lonicera japonica). Invasive exotic and nuisance plants are 

typically fast growing hardy species that out-compete native species for nutrients, sunlight, and space. 

These species may be difficult to control due to aggressive and efficient reproduction patterns, as well as 

a lack of natural controls, such as insects and herbivores. 

4.4.3 Wetlands 

Section 404 of the CWA protects the jurisdictional waters of the United States, including 

wetlands. “Wetlands” is a collective term for swamps, marshes, bogs, wet meadows, and similar areas 

that are often located between open water and dry land. A wetland is defined as an area that is inundated 

or saturated by surface water or groundwater at a frequency and duration sufficient to support, and that 

under normal circumstances does support, a prevalence of vegetation typically adapted for life in 

saturated soil conditions, commonly known as hydrophytic vegetation (COE 1987). 

Bayou Casotte Energy identified wetland areas using desktop evaluation of National Wetland 

Inventory Maps, United Stated Geologic Survey 7.5 Minute Quadrangle Topographic Maps, and aerial 

photography, followed by field delineations at the terminal site in April 2005 and along the proposed 

pipeline interconnects and NGL pipeline route in April and December 2005. Field delineations were 

performed according to the COE Wetland Delineation Manual (COE 1987). Wetland boundaries were 

surveyed and the linear distance and acreage of impact to wetlands in the Project area were calculated by 

overlaying the proposed terminal and aboveground facility boundaries and construction rights-of-way on 

the surveyed wetland boundaries. Wetland jurisdictional determinations are usually valid for at least five 

years unless the land is altered. The COE is responsible for approving wetland delineations and 

permitting all wetland impacts. COE staff and Bayou Casotte Energy completed field verification of the 

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wetlands and waterbodies that would be affected by the proposed Project in January 2006. Though 

Hurricane Katrina is likely to have had a short-term impact on freshwater wetlands in the Project area, 

additional surveys, as well as field verification efforts, were completed following the effects of that storm. 

All wetlands that would be impacted by the proposed terminal and pipeline facilities were 

described using the Classification of Wetland and Deepwater Habitats of the United States (Cowardin et 

al. 1979). Wetlands identified by Bayou Casotte Energy were classified as palustrine emergent (PEM), 

palustrine scrub-shrub (PSS), palustrine forested (PFO), estuarine emergent (EEM), or estuarine scrubshrub (ESS) based on their primary vegetative stratum. Descriptions of these classifications are 

summarized below. 

Freshwater wetlands dominated by erect, herbaceous vegetation (e.g., grasslands or stands of 

reedy growth) are classified as PEM wetlands. This wetland type generally has less than 20 percent 

coverage by shrubs or trees. Freshwater wetlands with extensive woody vegetation less than 20 feet tall 

are classified as PSS wetlands. PSS wetlands generally have greater than 60 percent coverage by shrubs 

and less than 20 percent coverage by trees. Freshwater wetlands with greater than 50 percent coverage by 

trees greater than 20 feet in height are classified as PFO wetlands. PFO wetlands often consist of an 

overstory dominated by deciduous, broad-leaved tree species and an assortment of herbaceous plants and 

vines that occur as ground cover and in the forest subcanopy. 

EEM wetlands are semi-enclosed by land but have open, partly obstructed, or sporadic access to 

the open ocean. Salinity in EEM wetlands may be periodically increased above levels found in the ocean 

due to evaporation, but they are typically diluted by freshwater runoff from the associated watershed. 

EEM wetlands are dominated by herbaceous vegetation and have less than 20 percent coverage by shrubs 

or trees, while ESS wetlands are dominated by woody vegetation less than 20 feet tall. 

4.4.3.1 LNG Terminal Facilities 

Twelve wetlands occur at the proposed terminal site (Table 4.4.3-1). These include eight 

freshwater wetlands, which are classified as PSS, PEM, PSS/PEM, or PFO wetlands, and four estuarine 

wetlands, which are classified as ESS and EEM wetlands. The freshwater wetlands total approximately 

66.2 acres. In general, all of these wetlands are of relatively low to medium quality due to the effects of 

prior disturbance at the site and prevalence of exotic and nuisance vegetation. The PSS wetlands at the 

terminal site contain a scrub-shrub layer dominated by Chinese tallow and black willow (Salix nigra) with 

an understory of spikerush (Eleocharis spp.) and cattail (Typha spp.), which is considered a nuisance 

species. Spikerush and cattail were the most common vegetative species in PEM wetlands. 

Approximately 45 percent, about 53.1 acres, of the wetlands that occur at the proposed terminal 

site are classified as ESS, with a much smaller amount of EEM and mixed ESS/EEM wetlands. These 

estuarine wetlands, which are located along the southern portion of the proposed terminal site, are 

considered to be of low to moderate quality. Vegetation in the EEM wetlands that occur at the terminal 

site is comprised mostly of panic grass (Panicum spp.), bulrush (Scirpus spp.), cogongrass, and black 

needlerush (Juncus romerianus). The ESS wetlands also contain these species, as well as shrubs such as 

Chinese tallow, wax myrtle (Myrica cerifera), common reed (Phragmites australis), and black willow. 

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TABLE 4.4.3-1 

Wetlands Affected by Construction and Operation of the Proposed Casotte Landing 

Project 

Wetland Identification 

Number 

Wetland 

Classification 

Area Affected During 

Construction (acres)a

Area Affected During 

Operation 

(acres)b

Terminal Site 

W1AJA001 PSS 7.8 7.8 

W1AJA002 PSS/PEM 10.0 10.0 

W1AJA003 PSS 18.7 18.7 

W1AJA004 PSS/PEM 2.5 2.5 

W1AJA005 PSS 0.2 0.2 

W1AJA006 PEM 0.1 0.1 

W1AJA007A PSS 20.4 20.4 

W1AJA007B PSS 6.5 6.5 

W1AJA007C (nontidal) ESS (non-tidal) 46.3 46.3 

W1AJA007C (tidal) ESS (tidal) 4.2 4.2 

W1AJA007D EEM (Spartina 

patens) (non-tidal) 2.4 2.4 

W1AJA007E 

EEM (Juncus 

roemerianus) (nontidal) 

0.2 0.2 

Pipeline Interconnects 

W1AJA009 PSS/EEM 0.5 0 

W1AJA010 EEM 12.0 0 

Meter Station (Interconnect Laterals) 

W1AJA010 EEM 1.5 0.9 

Meter Station (Interconnect Spur) 

W1AJA010 EEM 1.3 0.9 

NGL Pipelinec

W1AJA015 PFO/PEM/PSS 2.1 0.2 

W1AJA014 EEM 3.7 0 

W1AJA013 PEM/PSS 0.6 0 

W1AJA011 PEM/PSS 2.3 0 

W1AJA012 PEM/PSS 2.4 0 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 4.4.3-1 (continued) 

Wetlands Affected by Construction and Operation of the Proposed Casotte Landing 

Project 

Wetland Identification 

Number 

Wetland 

Classification 

Area Affected During 

Construction (acres)a

Area Affected During 

Operation 

(acres)b

Meter Station (NGL Pipeline)c 

W1AJA012 PEM/PSS 1.2 0.7 

Totals 146.9 122.0 

_______________ 

Notes: 

a

 Includes the terminal site and the temporary and permanent construction rights-of-way and extra workspaces. 

b

 Operational impacts for the LNG terminal and meter stations include the permanent loss of wetlands within the 

footprint of those facilities. Operational impacts for the pipeline facilities would only result where a 10-foot wide 

strip (centered over the pipeline) maintained as herbaceous wetland resulted in a conversion of forested wetlands. 

c The NGL pipeline and meter station are nonjurisdictional facilities. 

PSS – Palustrine Scrub-Shrub 

PEM – Palustrine Emergent 

PFO – Palustrine Forested 

ESS – Estuarine Scrub-Shrub 

EEM – Estuarine Emergent 

4.4.3.2 Interconnect Pipeline Route 

The proposed jurisdictional pipeline interconnects and meter stations would affect a total of two 

wetlands comprising 15.3 acres (Table 4.4.3-1), although one wetland (W1AJA010) would be separately 

affected by the interconnects and both meter stations. These wetlands are classified primarily as EEM, 

with a minor PEM component, and all are considered to be of medium quality. As these wetlands occur 

in low areas between or adjacent to roadways, hurricane levees, and spoil piles, they have been subjected 

to previous disturbance. Dominant plant species present at these EEM wetlands include black needlerush 

(Juncus roemerianus), cordgrass (Spartina spp.), and panic grass. The PEM are dominated by cattails 

and soft rush (Juncus effusus). 

4.4.3.3 Nonjurisdictional Facilities 

The nonjurisdictional NGL pipeline and associated meter station would affect five wetlands, 

totaling approximately 12.3 acres (Table 4.4.3-1), although one wetland (W1AJA012) would be 

separately affected by both of these facilities. These wetlands are mostly classified as PEM/PSS, with 

smaller EEM and PFO components. In general, these wetlands are of medium quality, but one EEM 

wetland (W1AJA014) was determined to be relatively undisturbed and of higher quality. The plant 

species present in these wetlands include panic grass, cordgrass, cattails, black needlerush, and loblolly 

pine (Pinus taeda). 

4.4.4 Impact and Mitigation 

The primary impact on vegetation from construction and operation of the proposed Project would 

be the temporary removal of vegetation from construction work areas and permanent alteration of 

vegetative cover at the proposed terminal site. Bayou Casotte Energy would use open-cut construction 

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techniques to install the entire length of the proposed pipeline interconnects and linear, nonjurisdictional 

facilities. However, Bayou Casotte Energy proposes to limit impacts to vegetation and wetlands by siting 

the LNG terminal in an existing, disturbed industrial site and overlapping or co-locating the 

nonjurisdictional linear facilities with existing rights-of-way through primarily industrialized areas. 

4.4.4.1 Upland Vegetation 

Approximately 117.1 acres of low quality vegetation would be affected by construction of the 

jurisdictional Project facilities associated with the proposed terminal site and pipeline interconnects. 

Most of this impact would be permanent, as development and operation of the terminal site would result 

in a permanent conversion of vegetative cover. The area at the proposed LNG terminal site would be 

completely graded, excavated, or otherwise modified to accommodate the proposed vessel slip and LNG 

terminal facilities. Following construction, upland areas not containing new infrastructure would be 

landscaped with gravel or turf grass. Although existing vegetation at the terminal site would be 

permanently impacted by the proposed Project, the vegetation is sparse, fragmented, and contains 

numerous exotic and invasive species. 

Construction of the pipeline interconnects would affect 2.1 acres of low quality vegetation 

associated with existing rights-of-way. Additionally, construction of the nonjurisdictional NGL pipeline 

and water circulation system would temporarily affect an additional 23.9 acres of low quality upland 

vegetation associated with the Chevron Pascagoula Refinery perimeter. Impacts to vegetation along the 

construction rights-of-way for these facilities would be temporary, as disturbed upland areas would be 

restored, with little or no expected loss of cover type due to maintenance of the permanent rights-of-way. 

During the initial phases of upland construction, the construction right-of-way would be cleared and 

graded where necessary to provide a sufficiently wide and relatively level surface for the passage of 

heavy construction equipment (typically a minimum of 25 feet wide). Vegetation would be removed 

either by mechanical cutting or by hand. Trees and shrubs would be cut only where necessary to 

accomplish the installation of the pipeline and other facilities, and in accordance with state and local 

regulations and permitting. 

To ensure successful restoration and revegetation, Bayou Casotte Energy would adhere to its 

Plan, as modified in this EIS (see Section 4.2.1), which includes installation of temporary erosion 

controls, permanent erosion control devices, soil compaction mitigation, soil additives, seeding, follow-up 

inspections, and monitoring. Revegetation would be considered successful if the density and cover of 

non-nuisance vegetation within areas disturbed by construction is similar to the density and cover in 

adjacent undisturbed areas. 

During operation, normal maintenance procedures along the pipeline interconnect right-of-way 

would include regular mowing and periodic removal of woody shrubs (frequency cannot be more than 

once every three years). Turf grasses at the terminal site would be maintained by regular mowing. This 

landscaping and maintenance program would also control the presence and spread of exotic and invasive 

plant species. 

Given the measures outlined above, the general low quality of the vegetation resources that would 

be affected by the proposed Project, and because this Project involves re-development of an existing 

disturbed industrial site for a new industrial use, we conclude that impacts to upland vegetation resources 

would not be significant. 

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4.4.4.2 Wetlands 

Bayou Casotte Energy would limit wetland impacts by reducing the proposed terminal footprint 

to the minimum size practicable and by positioning the reduced footprint within the previously disturbed 

areas or lower quality wetland zones, as described in Section 3.4. Construction at the proposed terminal 

site and the jurisdictional and nonjurisdictional meter stations would result in a permanent conversion of 

affected wetland areas to maintained upland areas (Table 4.4.3-1). These wetlands include approximately 

122.0 acres of palustrine and estuarine wetlands. Some wetland functions and wildlife habitat would be 

lost in the permanent conversion of wetland areas to uplands. Wetland loss could also affect water 

retention and recharge for the underlying aquifers, as would the removal of existing vegetation. However, 

the affected wetlands are of low to moderate quality and have limited functional value. Additionally, 

higher quality wetlands in surrounding areas would continue to provide functional benefits and wildlife 

habitat, such that permanent impacts would be relatively minor overall. 

The impact of pipeline construction activities on wetlands could include the permanent and 

temporary alteration of wetland vegetation. Bayou Casotte Energy proposes to use open cut construction 

techniques to install the jurisdictional pipeline interconnects and the nonjurisdictional NGL. These 

activities would temporarily affect approximately 23.6 acres of predominantly moderate quality, estuarine 

and palustrine wetlands during construction (Table 4.4.3-1). The lone high quality EEM wetland 

(W1AJA014) that would be affected by construction of the nonjurisdictional NGL pipeline would not be 

permanently affected by operations, but construction of that facility would result in the permanent 

conversion of 0.2 acres of forested wetland (W1AJA015). Thus, the impact of proposed pipeline 

construction activities on wetlands would include the permanent and temporary alteration of wetland 

vegetation. Other impacts associated with construction of the proposed pipeline could include temporary 

changes to wetland hydrology, water quality (e.g., hazardous materials spills), and erosion/sedimentation. 

Effects typically would be greatest during and immediately following construction. 

Construction and restoration of wetlands for the pipeline interconnects would be conducted in 

accordance with the Bayou Casotte Energy’s Procedures, as modified in this EIS (see Section 4.3.2). 

Although the Bayou Casotte Energy requested expansion of the construction right-of-way in wetlands to 

110 feet, the construction right-of-way in wetlands would be limited to 75 feet or less, unless site-specific 

approval for exceptions were granted by the Commission. During construction, protective measures 

would include, but not be limited to: marking of wetland buffers, location of all extra work areas at least 

50 feet from wetlands, limitation of vegetative clearing, limitation of equipment operating in the wetland, 

and installation of temporary sediment controls. 

Prior to construction, Bayou Casotte Energy would develop a Project-specific restoration plan in 

consultation with the COE and MDMR. Restored wetlands would be monitored by a qualified biologist 

annually for three years, followed by submittal of a report regarding the success of restoration to the 

Commission. If after two years of monitoring, the vegetation did not consist of at least 80 percent 

wetland species, appropriate native wetland species would be planted. If restoration is not considered 

successful after three years, monitoring would continue annually and a remedial revegetation plan would 

be developed. Bayou Casotte Energy’s proposed Procedures, as modified in this EIS, would restrict 

maintenance activities in wetlands to a 10-foot-wide corridor centered on the pipeline, which could 

include regular mowing and periodic removal of woody shrub and tree species at a frequency not 

exceeding once every three years. 

4.4.5 Compensatory Mitigation 

For projects where wetland impacts are proposed, the COE requires that all appropriate and 

practicable actions be taken to avoid or minimize those impacts, pursuant to its Section 404(b)(1) 

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guidelines that restrict discharges of dredged or fill material where a less environmentally damaging and 

practicable alternative exists. All wetland crossings would be subject to review by the COE and MDMR 

under the Joint Section 404 permitting process. Bayou Casotte Energy submitted its Joint Permit 

Application with the COE on July 27, 2006. 

To mitigate for unavoidable loss of wetland function if the proposed Project were approved, 

Bayou Casotte Energy proposed a wetland mitigation plan in its Joint Permit Application following 

consultation with the FWS, COE, and MDMR. Bayou Casotte Energy is considering several mitigation 

options, including restoration and enhancement of a local site and the purchase of mitigation credits from 

various mitigation banks and restoration projects. These options include Moss Point Mitigation Bank, 

Old Fort Bayou Mitigation Bank, and Round Island, Greenwood Island and Deer Island restoration 

projects. Mitigation banking is an approved alternative to on-site mitigation and often provides for 

greater likelihood of success in replacement of wetland function and long-term management of restored 

wetland areas. The proposed mitigation ratios are 1:1 for temporary construction-related impacts, 2:1 for 

permanent impacts, and 4:1 for permanent high-saltmarsh impacts. 

Given the previously disturbed nature and relatively low quality of the wetlands that would be 

affected by the proposed Project, the measures that would be used to prevent or minimize effects, 

including Bayou Casotte Energy’s Procedures, as modified in this EIS, and the requirement that Bayou 

Casotte Energy complete permitting and develop an agency approved wetland mitigation plan prior to 

construction, we conclude that impacts to wetland resources associated with construction and operation of 

the proposed Project would not be significant. 

4.5 WILDLIFE AND AQUATIC RESOURCES 

This section describes the terrestrial, fresh water, estuarine, and marine wildlife species and 

habitats that occur or could potentially occur in the area that would be affected by construction and 

operation of the proposed Project, including the waterway used by the LNG marine traffic to transit from 

the territorial sea to the berthing facility, and describes the potential effects on those species. 

4.5.1 Terrestrial Wildlife 

4.5.1.1 Existing Terrestrial Wildlife Habitats 

The proposed Casotte Landing Project is located in the Coastal Plain region of southern 

Mississippi. The onshore habitats supporting terrestrial wildlife in the vicinity of the proposed Project 

have been extensively modified by past development and industrial uses. The proposed Project would redevelop these previously disturbed lands. Onshore habitats supporting terrestrial wildlife include upland 

habitats, open water habitats, and wetlands, as described in Sections 4.3 and 4.4. LNG marine traffic 

would also transit confined areas between the barrier islands and the mainland where submerged aquatic 

vegetation and beach dunes occur. The wildlife and aquatic resources associated with submerged aquatic 

vegetation is discussed in Section 4.5.2.1. Additional information on the environmental impacts resulting 

from the transit of the LNG ships is provided in Section 4.12.5.3. 

Upland Habitats 

Two categories of upland habitat occur at the proposed terminal site and along the proposed 

pipeline interconnects: right-of-way associated vegetation (2.1 acres) and commercial/industrial 

associated vegetation (115.0 acres, with an additional 23.9 acres affected by nonjurisdictional facilities). 

The proposed terminal site and upland areas located at the pipeline interconnects are heavily disturbed 

and are located in a previously developed area in an industrial setting. The vegetation types and habitats 

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present are representative of this disturbance and as such are sparse, fragmented, and of generally low 

quality. No forested upland areas occur at the proposed terminal site or along the proposed pipeline 

interconnects, and those upland areas that are present offer little to no habitat for wildlife foraging, 

resting, or nesting. Species that may occur at the proposed Project site are typical of disturbed or 

developed areas in the Coastal Plain, and a list of representative species is included in Table 4.5.1-1. 

TABLE 4.5.1-1 

Typical Wildlife Species that Occur in the Vicinity of the 

Proposed Casotte Landing Project 

Common Name Scientific Name 

Opossum Dildelphis virginiana 

Raccoon Procyon lotor 

Red shouldered hawk Buteo lineatus 

Great blue heron Ardea herodias 

Turkey vulture Cathartes aura 

Bullfrog Rana catesbiana 

American alligator Alligator mississippiensis 

Five-lined skink Eumeces fasciatus 

Gray rat snake Elaphe obsoleta 

Open Water 

Fourteen onshore waterbodies occur at the proposed terminal site, and two onshore canals would 

be traversed by the pipeline interconnects. Additionally, the nonjurisdictional NGL pipeline would cross 

five perennial ditches and one perennial canal. 

Virtually all of the onshore waterbodies that would be affected by the proposed Project are 

artificially constructed canals, ditches, or ponds that offer minimal habitat for aquatic species. Only one 

onshore waterbody (S1AJA020), a tidally influenced creek that would be affected by the nonjurisdictional 

NGL pipeline, was identified as a natural waterbody. The only fish species observed by Bayou Casotte 

Energy during field surveys and known to occur in the onshore waterbodies and wetlands at the proposed 

terminal site is the striped mullet (Mugil cephalus). Additionally, blue crabs (Callinectes sapidus) and 

fiddler crabs (Uca pugnax) were observed in onshore waterbodies during field surveys. These 

waterbodies (and wetlands) also undoubtedly provide habitat to migratory birds and waterfowl such as 

ducks and geese, but the habitat is of relatively low quality. Onshore waterbodies are discussed in more 

detail in Section 4.3.2, and potential impacts to these habitats are discussed below. 

Wetlands 

A variety of wetlands and wetland types occur at the proposed terminal site and along the 

proposed pipeline interconnects. The quality of wetlands at the proposed terminal site, considering such 

factors as the potential for wildlife utilization, has been compromised by extensive alteration and historic 

disturbance that has occurred at the site. Intertidal estuarine emergent or estuarine scrub-shrub wetlands 

of low to medium quality comprise 53.1 acres at the proposed terminal site. Other wetlands at the 

terminal site (approximately 66.2 acres) are classified as palustrine scrub-shrub or palustrine emergent, 

and are also considered to be of low to medium quality. Wildlife typical of wetlands found onsite are 

listed in Table 4.5.1-1. 

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Jurisdictional facilities associated with the proposed pipeline interconnect routes and meter 

stations would traverse wetland areas classified as estuarine emergent (15.0 acres) and palustrine scrubshrub (0.3 acres). Nonjurisdictional facilities, such as the NGL pipeline and associated NGL pipeline 

meter station, would traverse wetlands classified as palustrine emergent (4.3 acres), palustrine scrubshrub (4.1 acres), estuarine emergent (3.7 acres), and palustrine forested (0.2 acres). Additional 

information regarding these wetlands is provided in Section 4.4 and potential impacts to these habitats are 

discussed below. 

Beach Dunes 

Beach dunes occur on Petit Bois and Horn Islands along the LNG ship transit route of the 

proposed project. Beach dunes provide foraging and resting habitats for various migratory and resident 

species of birds throughout the year, including brown pelican, great blue heron, gulls, terns, and osprey 

(Pandion haliaetus). In addition, marsh rabbit (Sylvilagus palustrus), cottontail rabbit, Norway rat, black 

rat (Rattus rattus), river otter (Lutra canadensis), and raccoon occur in the beach dune habitat. 

4.5.1.2 Unique or Sensitive Wildlife Habitats 

The proposed pipeline interconnect spur would approach, but not cross, the boundary of the 

Grand Bay Reserve, an 18,400 acre tract preserved and managed by NOAA Fisheries and the MDMR. 

The Reserve contains numerous habitats for wildlife including coastal bay, saltwater marshes, pine forest, 

pine savannas, and pitcher plant bogs (NOAA 2006a). The Grand Bay Reserve is located approximately 

1.0 mile east of the proposed terminal site. No other unique or sensitive habitats occur in the vicinity of 

the proposed Project. 

4.5.1.3 Impacts and Mitigation 

Upland Habitats 

Construction and operation of the proposed Project could result in relatively minor direct and 

indirect effects on wildlife and their habitats. Additional discussion regarding potential impacts to 

vegetated areas is provided in Section 4.4. Upland habitats include vegetation associated with existing 

commercial/industrial land, and to a much smaller extent, existing rights-of-way. However, more suitable 

and higher quality habitats are located adjacent to the proposed Project, particularly at the Grand Bay 

Reserve. 

Direct effects to marginal and fragmented wildlife habitats would include temporary effects along 

the proposed interconnects and permanent alteration of habitats at the terminal site; displacement or 

mortality during construction; and disturbance, alteration, and loss of habitat from maintenance activities 

once construction is completed. Clearing of vegetation for construction and operation could reduce cover, 

nesting, and foraging habitat for wildlife. During construction, mobile species would be displaced from 

the construction right-of-way while less mobile species, such as small mammals, reptiles, and amphibians 

could be injured or killed. Routine operation activities, such as maintenance of the proposed pipeline 

interconnects, could result in similar but less extensive effects on wildlife species. Indirect effects to 

wildlife species may include disturbance from noise and human activity during construction and 

temporary impacts to water quality. Bayou Casotte Energy has proposed to contract licensed wildlife 

specialists to remove and relocate any large specimens of wildlife, such as alligators, that presently occur 

at the proposed terminal site prior to excavation. Fencing or other barriers would be used to keep wildlife 

from re-entering the site after removal. 

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The proposed Project is located in an area traversed by migratory birds as they move between 

northern breeding grounds and southern wintering grounds. Given the location of the proposed Project, 

migrating birds could encounter the proposed terminal facilities immediately before or just after crossing 

the Gulf of Mexico. Many of the birds that cross the Gulf of Mexico are nocturnal migrants and these 

species can become disoriented by lights at various facilities, especially towers. During an interagency 

scoping meeting for the project, the FWS expressed concerns that migratory birds could be adversely 

impacted by lighting at the proposed LNG terminal. The FWS has developed lighting guidelines for the 

siting, construction, operation, and decommissioning of communication towers that specifically 

recommend the number and intensity of facility lighting be minimized and that security lighting be downshielded to keep light within the boundaries of the site. To address potential impacts from terminal 

lighting on migratory birds, we recommend that: 

• Bayou Casotte Energy should develop a lighting plan consistent with the lighting 

guidelines developed by the FWS for siting, construction, operation, and 

decommissioning of communication towers, to the extent that those guidelines are 

consistent with applicable safety regulations and requirements, and file that plan with 

the Secretary for review and written approval by the Director or OEP prior to 

construction. 

Open Water 

All onshore waterbodies at the proposed terminal site would be filled, graded, or otherwise 

removed during site preparation and excavation and permanently converted to uplands. This impact 

would result in a loss of low quality aquatic habitat for striped mullet, blue and fiddler crabs, water birds, 

and some upland species. Fish, other aquatic life, and less mobile species could suffer mortality during 

construction. However, these impacts are considered relatively minor as more suitable and higher quality 

habitats, and greater wildlife species diversity and abundance are located in close proximity to the 

proposed terminal site, particularly at the Grand Bay Reserve. 

Bayou Casotte Energy proposes to use open-cut techniques to accomplish installation of the 

jurisdictional pipeline interconnects across two waterbodies. Additionally, open-cut methods would be 

used to install the nonjurisdictional NGL pipeline across six perennial waterbodies. In order to minimize 

potential environmental impacts, the NGL pipeline would be completely co-located with the proposed 

interconnect spur, the existing Gulfstream pipeline, and the existing MPC electric transmission line rightof-way. Virtually all of the waterbodies affected by the proposed pipeline interconnect and NGL pipeline 

represent man-made features located in a previously disturbed, heavily impacted area, and are generally 

of low quality. Additionally, all impacts to those features would be temporary, as the waterbody 

crossings would be restored in accordance with Bayou Casotte Energy’s Procedures, as modified in this 

EIS (see Section 4.3.2), following pipeline installation. Additional measures to limit impacts and mitigate 

for permanent impacts to existing onshore waterbodies and aquatic species may also be required as 

conditions of the permits that may be granted by other agencies including the COE, MDMR, and MDEQ. 

Given the relative low quality of the onshore waterbodies crossed by the proposed pipeline interconnects 

and NGL pipeline, as well as required measures to prevent or minimize impacts, we conclude that the 

crossings would not result in more than a temporary, relatively minor negative effect to onshore, fresh 

water habitats. 

Wetlands 

Construction at the proposed terminal site would result in a permanent conversion of all wetland 

areas to maintained upland areas, as these areas would be filled or otherwise removed as described in 

Section 4.4.3. These areas include approximately 119.3 acres of low to medium quality palustrine and 

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estuarine wetlands. Bayou Casotte Energy also proposes to use open-cut construction techniques to cross 

two medium quality, palustrine emergent and estuarine emergent wetlands associated with the installation 

of the pipeline interconnects. These activities would affect approximately 12.5 acres of wetlands. The 

impacts associated with the pipeline interconnects would all be temporary, as the emergent wetlands 

would be restored following construction and the removal of any woody vegetation during operations 

would focus on a 10-foot-wide right-of-way centered directly over the pipeline. Construction of the two 

jurisdictional meter stations would also affect 2.8 acres of estuarine emergent wetlands, and 1.8 of those 

acres would be permanently converted to uplands. Additionally, construction of the nonjurisdictional 

NGL pipeline and associated meter station would affect 12.3 acres of mostly palustrine emergent and 

palustrine scrub-shrub, medium quality wetlands. Operations would affect only 0.9 acres. 

The impact of the proposed pipeline construction activities on wetland wildlife habitats could 

include the permanent and temporary alteration of wetland vegetation, temporary changes to wetland 

hydrology, and erosion/sedimentation. Loss of wetland habitat could result in displacement of species 

dependent on these habitats, such as wading birds, waterfowl, and amphibians. Less mobile species could 

suffer mortality during construction activities. Effects typically would be greatest during and 

immediately following construction. Construction through and restoration of wetlands for the pipeline 

interconnects and nonjurisdictional NGL pipeline would be conducted in accordance with Bayou Casotte 

Energy’s Procedures, as modified in this EIS (see Section 4.3.2). These measures would limit the 

potential for impacts to wetlands and aquatic species associated with installation of the pipeline 

interconnects. 

In general, the marginal onshore habitats that would be affected by the proposed Project are 

highly disturbed, industrialized, and support limited amounts of wildlife. However, more suitable and 

higher quality habitats are located adjacent to the site, particularly at the Grand Bay Reserve. All 

construction would be conducted in accordance with the mitigation and restoration requirements 

described in Bayou Casotte Energy’s Plan and Procedures, as modified in this EIS (see Sections 4.2.1 and 

4.3.2), and impacts to onshore wildlife habitat would be minimal. Given these measures, the extremely 

limited amounts of available upland habitats available, and the limited number and low abundance of 

species present, we conclude that the proposed Project would not result in a significant effect to any 

terrestrial or freshwater wildlife resources. 

Additional information on the environmental impacts resulting from LNG ships and transit is 

provided in Section 4.12.5.3. 

4.5.2 Estuarine and Marine Resources 

The proposed Casotte Landing Project would be located on Bayou Casotte, an estuary emptying 

into the Pascagoula Bay/Mississippi Sound portion of the Gulf of Mexico. The open waters of the 

estuarine area provide wintering habitat for a wide variety of bird species, including brown pelican 

(Pelecanus occidentalis), American white pelican (Pelecanus erythrorhynchos), loons, grebes, and ducks. 

Bottlenose dolphins (Tursiops truncatus) and Atlantic spotted dolphins (Stenella frontalis) may also occur 

in the marine habitat along the proposed LNG marine traffic route. 

Fish communities occupying the nearshore areas consist of species found in both estuarine and 

offshore marine habitats. Distribution and abundance of fish species and communities within these 

habitats vary greatly with time and place, depending on factors such as temperature, salinity, and 

predictable cycles directly related to reproduction. 

Life histories of many fish species in the Gulf of Mexico can be characterized as estuarinedependent. These species typically spawn in the Gulf, while the juvenile fish generally remain in the 

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estuarine nurseries for about a year, taking advantage of the greater availability of food and protection 

that estuarine habitats afford. Upon reaching maturity, estuarine fish either remain in the estuary, migrate 

to sea to spawn (returning to the estuary between spawnings), or migrate from the shallow estuaries to 

spend the rest of their lives in deeper offshore waters. Non-estuarine fish, including coastal pelagic 

marine fish and freshwater fish, will also forage in estuaries when conditions are favorable. 

4.5.2.1 Existing Estuarine and Marine Resource Habitats 

The proposed Casotte Landing Project would potentially impact three estuarine and marine 

habitats: estuarine soft bottom and its overlying water column, marine soft bottom and its overlying 

water column, and submerged aquatic vegetation. Other estuarine and marine habitats exist in the Bayou 

Casotte and Mississippi Sound area that are not expected to be affected by the proposed action. These 

habitats include coastal marshes and oyster reefs. 

Estuarine Soft Bottom and Water Column Habitats 

The benthic habitat of Bayou Casotte is comprised of marine silts combined with fine to very fine 

sands. Bayou Casotte is an existing, industrialized shipping channel already subject to routine 

maintenance dredging, which is performed approximately every three years by the COE. Therefore, the 

estuarine benthic habitat in this area is already frequently disturbed. The fauna associated with this 

benthic habitat is reflective of periodic disturbance and is primarily comprised of opportunistic and 

colonizing invertebrate species. Typical benthic species associated with this habitat type are listed in 

Table 4.5.2-1. 

TABLE 4.5.2-1 

Typical Estuarine Benthic Species that Occur in the Vicinity of the 

Proposed Casotte Landing Project 

Group Scientific Name 

Hemichordate Balanoglossus cf. aurantiacus 

Mulinia lateralis 

Nassarius acutus 

Mollusk 

Utriculastra canaliculata 

Armandia maculata 

Capitella capitata 

Heteromastis filiformis 

Magelona sp. H 

Mediomastus sp. 

Owenia fusiformis 

Polychaete 

Paraprionospio pinnata 

The aquatic habitat occurring in the Bayou Casotte water column is also reflective of a developed 

and previously disturbed setting. Bayou Casotte is listed as an impaired waterbody (i.e., impaired ability 

to support aquatic life) by the MDEQ due to the presence of total toxics and unionized ammonia (MDEQ 

2005). The estuary is turbid, with typical turbidity levels of 15 NTUs or greater, and with levels of TSS 

present averaging 55 mg/l. Fertilizer manufacturers located within the Bayou Casotte watershed 

contribute nitrogen and phosphorus, which are sources of nutrient enrichment, and Mississippi Sound, 

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including Bayou Casotte, is subject to periodic episodes of reduced dissolved oxygen levels. The water 

resources of Bayou Casotte are discussed in more detail in Section 4.3.2. 

Marine Soft Bottom and Water Column Habitats 

Bayou Casotte Energy proposes to dispose of sediments dredged from the proposed terminal slip 

at the EPA’s permitted Pascagoula ODMDS, which is located approximately 11 nautical miles offshore in 

the Gulf of Mexico south of Horn Island. The disposal of dredged sediments at the Pascagoula ODMDS 

was evaluated in an EIS prepared by the EPA (1991), in coordination with the U.S. Navy and COE as 

cooperating agencies. According to the EPA (1991), sediments at the ODMDS were highly variable and 

range from mostly sand to a silt-clay mixture. In general, sediment quality in this area was relatively 

good. Laboratory analyses of sediment samples collected in the vicinity of the ODMDS indicated that 

chemical constituents either were not detected or were found in concentrations similar to other locations 

typical of the Gulf of Mexico. Water quality in this area is variable, with issues including seasonally low 

levels of dissolved oxygen, but levels of contaminants were generally found to be lower in waters at the 

ODMDS than in other offshore waters in the vicinity. The benthic community at the ODMDS is 

dominated by polychaetes (including several of the species listed in Table 4.5.2-1), nemertean worms, 

sipunculid worms, and small crustaceans (EPA 1991). Common fish species found at the ODMDS 

include those listed in Table 4.5.2-2. The EPA (1991) concluded that disposal of dredged sediments 

would not significantly affect the long-term productivity of the ODMDS site and mandated monitoring 

and management programs to prevent impacts. 

Submerged Aquatic Vegetation 

LNG marine traffic would transit confined areas between the barrier islands and the mainland, 

where submerged aquatic vegetation and beach dunes occur. Submerged aquatic vegetation, or seagrass, 

occurs in relatively shallow coastal waters of the Mississippi Sound as a result of depth-limited 

penetration of sunlight associated with the relatively turbid waters of the coast. These communities 

provide food for the marine ecosystem. In addition, they provide cover for many young fish. Although 

the seagrass beds make up only a small percentage of the total submerged lands, the fauna observed in 

association with them, especially the invertebrates, appears far greater than the more extensive sandy 

areas. Typical motile benthic species utilizing seagrass habitat includes gastropods such as the convex 

slippershell (Crepidula convexa). Seagrass beds provide habitat and protection for a wide variety of 

larval and juvenile species such as bay scallops (Argopecten irradians), gray snapper (Lutjanus griseus), 

black drum (Pogonias cromis), and code goby (Gobiosoma robustum) that feed on the smaller animals 

also utilizing the beds (Nelson 1992). In addition, green sea turtles (Chelonia mydas), Kemp’s ridley sea 

turtles (Lepidochelys kempii), and smalltooth sawfish (Pristis pecinata) are known to occur in seagrass 

beds. 

Fisheries of Special Concern 

Fish species of special concern that occur in the vicinity of the proposed project include federal 

and state listed threatened and endangered species, those with EFH designations in the Mississippi Sound 

estuary, and those of commercial and recreational value. Threatened and endangered fish species are 

discussed in Section 4.6. Species having EFH designations, as well as commercial and recreational fish 

species, are discussed below. 

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TABLE 4.5.2-2 

Managed Fish and Shellfish Resources with Potential for EFH in the 

Casotte Landing Project Area 

Common Name 

(applicable to all life stages unless otherwise noted) Scientific Name 

Brown shrimp Farfantepenaeus aztecus

White shrimp Litopenaeus setiferus

Pink shrimp Farfantepenaeus 

duorarum

Red drum Sciaenops ocellatus

Gag grouper Mycteroperca microlepis

Gray snapper 

(juveniles and adults only) 

Lutjanus griseus

Red snapper (juveniles only) Lopholatilus 

chamaeleonticeps

Lane snapper 

(juveniles only) 

Lutjanus synagris

King mackerel 

(juveniles only) 

Scomberomorus cavalla

Spanish mackerel 

(juveniles and adults only) 

Scomberomorus 

maculatus

Cobia 

(juveniles and adults) 

Rachycentron canadum

Stone Crab 

(all stages but rarely found) 

Menippe mercenaria

Gulf Stone Crab Menippe adina

Scalloped hammerhead shark 

(rarely found, late juvenile/subadult) 

Sphyrna lewini

Blacktip shark 

(rarely found, late juveniles) 

Carcharhinus limbatus

Tiger shark 

(rarely found, juveniles only) 

Galeocerdo cuvieri

Bonnethead shark Sphyrna tiburo

Atlantic sharpnose shark 

(all stages, but rarely found) 

Rhizoprionodon 

terraenovae

Commercial and Recreational Fisheries 

A variety of fish and shellfish species occur in the Gulf of Mexico. A list of the representative 

species managed by NOAA Fisheries that may occur in the estuarine and marine waters of Bayou 

Casotte, the Mississippi Sound, and the Gulf of Mexico are included in Table 4.5.2-2. Although Bayou 

Casotte serves as a launching point for recreational fishing charters, most fishing activity in the area is 

conducted outside of Bayou Casotte. There are no commercially harvested fish or shellfish populations in 

Bayou Casotte. The oyster fisheries nearest the proposed Project are located in Point-aux-Chenes Bay 

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(approximately 0.5 miles southeast of the proposed terminal site) and at Bangs Lake (approximately 

1.7 northeast of the proposed terminal site). 

4.5.2.2 Impacts and Mitigation 

Short-term and permanent impacts to estuarine and marine habitats resulting from construction 

and operation of the proposed Project are discussed below. 

Impacts to Estuarine Soft Bottom and Water Column Habitats 

Potential impacts related to construction at the proposed terminal site that could affect the 

estuarine water column and soft bottom habitat include runoff from the terminal site during excavation 

and construction; sedimentation, turbidity, and possible mobilization of contaminants associated with 

dredging of the terminal slip; accidental spills; and withdrawal and discharge of hydrostatic test water. 

These impacts are discussed below and also in Section 4.3.2. 

Impacts Resulting from Construction

Excavation and Runoff 

Construction of the proposed terminal slip would require the excavation and removal of 

approximately 1.0 mcy of soil located at or above the water table. Some of the excavated material would 

be stockpiled on-site and used for fill, leveling, and construction of the proposed LNG terminal. 

Significant stormwater runoff resulting from excavation activities could result in re-suspension of soil 

particles into the water column and settling of these particles over existing estuarine soft bottom habitats. 

In addition, stormwater runoff could result in increased nutrient loads or contamination to aquatic 

systems, dependent on the types and concentrations of constituents associated with the suspended 

materials. Significant concentrations of nutrients or contaminants could cause decreases in survival, 

growth and reproduction of aquatic organisms receiving sufficient exposure. In addition, re-suspension of 

soil particles could increase turbidity, resulting in impacts to both sessile and mobile aquatic species. 

Increases in turbidity physiologically affect aquatic resources (e.g., fish) through mechanical abrasion of 

surface membranes, delayed larval and embryonic development, reduced bivalve pumping rates, or 

interference with respiratory functions. In addition, fish could be affected behaviorally through 

interference with feeding for sight-foraging fish and area avoidance. Reduced visibility of predatory fish 

could also lower vulnerability to predation for prey species. Settling of soil particles over existing bottom 

sediments (if significant) could result in loss of habitat for sessile species of invertebrates and plants and 

could also disrupt oxygen transport mechanisms for many species. 

In order to control and minimize runoff from the terminal site to Bayou Casotte during 

construction, Bayou Casotte Energy would implement its Plan, as modified in this EIS, and its SWPPP 

(see Appendix C). Bayou Casotte Energy’s Plan provides for installation of temporary and permanent 

erosion control measures such as silt fencing/straw bales, slope breakers, sediment barriers, interceptor 

dikes, mulch, and trench breakers; re-vegetation; daily inspection of cleared areas; and monitoring and 

maintenance of previously disturbed areas. Additionally, Bayou Casotte Energy would have to comply 

with any other erosion control and BMP provisions that may result from ongoing consultations with 

MDMR, COE, and NOAA Fisheries. 

Dredging 

Following excavation of soils above the water table, approximately 3.5 mcy of sediments would 

be removed from the proposed terminal slip using a mechanical dredge. This activity would disturb 

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approximately 6.3 acres of unvegetated, soft bottom habitat, although construction of the proposed slip 

would result in the creation of approximately 49 acres of new, soft bottom habitat. In addition to directly 

removing benthic substrate and sessile organisms inhabiting the substrate, dredging would also 

temporarily increase turbidity and sedimentation in the area surrounding dredging operations. 

Sedimentation could result in injury or mortality to benthic organisms through burial or smothering, but it 

is anticipated that these organisms would re-colonize the area soon after cessation of the dredging 

activity. However, suspended sediments would likely settle relatively quickly. As described above, 

increases in turbidity, if significant, could result in physiological effects and/or behavioral modifications 

by aquatic organisms. Any turbidity effects would be limited to the dredging period as suspended 

sediments would likely return to background levels relatively quickly. 

Bayou Casotte Energy modeled the potential for suspension of sediments associated with 

dredging of the slip using the COE’s DREDGE model. The resulting analysis indicated that TSS levels 

generated by dredging would be similar to or lower than ambient levels occurring in Bayou Casotte. 

Potential impacts to marine water resources associated with the proposed dredging activities would be 

small given the relatively low levels of TSS that would be generated and considering that the area is 

already routinely subjected to periodic COE maintenance dredging (and suspension of sediments into the 

water column) for the federal Bayou Casotte shipping channel. 

Bayou Casotte Energy is consulting with MDEQ, MDMR, COE, and NOAA FISHERIES 

regarding the development of BMPs to reduce sedimentation and turbidity during dredging, as well as the 

need for and requirements of any monitoring programs. In Section 4.3.2, we have recommended that 

Bayou Casotte Energy complete these ongoing consultations and finalize any needed measures to prevent 

or minimize impacts prior to construction. Bayou Casotte Energy consulted with NOAA Fisheries 

regarding seasonal construction windows which are sometimes implemented to reduce impacts to aquatic 

species, including managed species. It was determined that NOAA Fisheries would not require seasonal 

construction windows. Bayou Casotte Energy has also consulted with the MDMR regarding the need for 

a pre-construction and post-construction project trawl and benthic sampling plan; however, MDMR has 

not yet reached a conclusion on a benthic sampling plan. Because these consultations are not yet 

complete, we recommend that: 

• Bayou Casotte Energy should complete consultations with MDMR regarding the need 

for a pre-construction and post-construction project trawl and benthic sampling plan 

and, if required, file the agency approved plan with the Secretary prior to construction. 

Mobilization of Contaminants 

Potentially contaminated soils and sediments at the terminal site have been identified and 

delineated during previous environmental site assessments. As previously discussed, excavation and 

dredging activities, and the associated stormwater runoff, have the potential to re-introduce deleterious 

compounds currently in the bottom sediments and surface soils into open water habitats surrounding the 

proposed terminal site. Certain chemical contaminants could cause various acute or chronic growth and 

physiological effects on a wide variety of species including fish, birds, mammal, reptiles, and amphibians. 

For this particular site, the known contaminated sediments are located at or near the ground surface, and 

Bayou Casotte Energy has proposed to remove them by focused excavation activities prior to any other 

grading or site preparation activities. Any contaminated sediments would be properly disposed of off-site 

in permitted landfills, thus removing the possibility of impacts to surface waters and associated fish and 

wildlife resources. 

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Accidental Spills 

Bayou Casotte Energy would use training and engineering controls to minimize the potential for, 

and effect of, any inadvertent spills at the proposed terminal site. Depending on the location, magnitude 

and type of spill, potential terrestrial and aquatic resources could be at risk. Most fuel related compounds 

have the ability to cause acute and chronic mortality on all levels of aquatic and terrestrial biota. In the 

event that significant volumes of material were spilled into surrounding waters, vegetation and other 

aquatic resources could be potentially affected. 

Bayou Casotte Energy has developed a SPCC Plan for construction activities (see Appendix D). 

Measures to prevent or minimize the effects of accidental spills during construction include adequate 

primary and secondary containment features, availability of spill kits, inspection of drainage from storage 

areas, and corrosion protection for buried piping. Programmatic guidelines in the SPCC Plan include spill 

reporting, notification of spills to relevant agencies, periodic review and evaluation of the plan, 

inspections, and training, and these measures are also discussed in Sections 4.2.1 and 4.3.1. Additionally, 

in Section 4.2.1, we have included a recommendation that Bayou Casotte Energy develop and finalize an 

operational SPCC Plan prior to the start of construction. 

Pile Driving 

Bayou Casotte Energy proposes to install approximately 265 pilings during construction of the 

marine berthing and unloading facilities. The piles would be approximately 100 to 140 feet long, with a 

diameter of 16 to 48 inches. They would be installed using a barge-mounted crane and various methods, 

including impact driving. 

In some cases, driving steel piles can generate intense underwater sound pressure waves that can 

adversely affect nearby marine organisms. 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 by 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 at a reference pressure of 1 micropascal 

(re: 1 μPa) can illicit avoidance behaviors or stun small fish (NOAA 2003). Sounds greater than 

190 decibels (re: 1 μPa) 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 piledriving activities may be more susceptible to predators). 

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 produces 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 because 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 (2003a) reported that all have 

occurred during use of an impact hammer on hollow steel piles. On the other hand, the rapid repetitions 

of vibratory hammers produce relatively low intensity sound waves. Evidence also suggests that fish 

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consistently display an avoidance response to sound from a vibratory hammer, even after repeated 

exposure (Dolat, 1997; Knudsen et al., 1997). 

Driving steel pipe piles with an impact hammer in similar settings has been shown to generate 

sound levels from 192 to 194 decibels (re: 1 μPa), 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 (re: 1 μPa) per foot (Nedwell and Edwards, 2002; Nedwell et al., 2003). Based on these 

values, the use of an impact hammer at the proposed LNG terminal could generate underwater sound 

levels great enough to injure, stun, or illicit avoidance responses (i.e., 155 decibels (re: 1 μPa)) in fish in 

the vicinity of the pile driving activities. Although the sound waves of the greatest intensity would be 

limited to the immediate vicinity of the piles within the unloading slip, sound levels of 155 decibels (re: 1 

μPa) could extend over 1,800 feet from a steel pile while piles for some of the mooring dolphins are being 

driven. Because dredging and other construction activities would be occurring both before and during 

pile installation, it seems likely many fish would avoid the area where the most intense sound levels 

would be generated. 

Based on consultations with NOAA Fisheries, Bayou Casotte Energy will adopt NOAA 

Fisheries’ Pile-Driving Harm Avoidance and Listed Species / Critical Habitat and Vessel Impacts

guidelines. These guidelines include alternative options to reduce potential impacts resulting from sound 

waves caused by pile driving. These options consist of reduction of sound waves by use of a bubble 

curtain, use of a smaller hammer type, or observation of a defined zone to monitor for sensitive species 

and adjustment of pile driving activity, as prescribed in the guidelines.

Increased Noise 

Construction of the proposed LNG terminal slip would result in increased noise in Bayou Casotte. 

The noise would result from increased vessel traffic associated with construction, dredging, pile driving 

(see above), pumping, and other incidental sounds. Noise can affect fish behavior, including feeding, 

habitat selection, and reproduction. However, given that these impacts would be temporary and that 

Bayou Casotte is an existing shipping channel that already is dredged every three years to maintain the 

channel by the COE, we conclude that impacts would be minor and fish and other mobile species would 

relocate to adjacent, unaffected areas for the duration of the disturbance. 

Hydrostatic Testing 

Bayou Casotte Energy would perform a hydrostatic test for structural integrity of the LNG 

transfer lines, storage tanks, and all pipelines prior to operation as described in Section 4.3.2. Hydrostatic 

test water would be withdrawn from Bayou Casotte and, after testing to assess suitability and need for 

treatment, it would be discharged back to Bayou Casotte at a rate and in a manner not causing erosion. 

Given its anticipated schedule, Bayou Casotte Energy estimates that hydrostatic testing would occur in 

the spring or summer seasons. Intake of water for hydrostatic testing could result in impingement and 

entrainment of fish and other aquatic biota. Impingement and entrainment has the potential to cause 

mortality, particularly to larval and other early life stages of aquatic species. Depending on factors such 

as the location of the intakes and timing, impingement and entrainment could cause significant reductions 

in recruitment and year class strength. In this section we have recommended that Bayou Casotte Energy 

complete consultations with NOAA Fisheries regarding seasonal construction windows to minimize the 

potential for adverse effects to aquatic species. During hydrostatic testing, Bayou Casotte Energy would 

comply with its proposed Procedures, as modified in this EIS, including provisions to screen water 

intakes to minimize impingement and entrainment of fish and other aquatic organisms. 

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Bayou Casotte Energy would also comply with the conditions of any NPDES permit that may be 

required by MDEQ in association with hydrostatic test water withdrawals. As certain hydrostatic test 

water additives may be toxic to aquatic life, Bayou Casotte Energy is in the process of consulting with 

MDEQ regarding the use of additives in hydrostatic test water, should their use become necessary. 

However, these consultations are not yet complete. Therefore, we have included a recommendation in 

Section 4.3.2 that requires Bayou Casotte Energy to consult with MDEQ and gain Commission approval 

before using any test water additives that could result in toxicity to aquatic organisms. 

Impacts Resulting from Operations

Stormwater Runoff 

Untreated and/or increased stormwater runoff can adversely affect the systems in which it 

discharges. Increased surface flows due to disturbance at the proposed terminal site could result in 

flooding and erosion. In addition, increased flows could result in increased turbidity and contaminant and 

nutrient loadings to surface water systems. In turn, this could result in acute and chronic toxicity to 

aquatic biota if not managed properly. 

Stormwater at the proposed terminal site would be routed by surface ditches and swales located 

adjacent to roads and the hurricane levee before collection in catch basins. Curbed areas would be used to 

contain spills and prevent contamination of storm water. Stormwater would collect in four basins and 

would ultimately be discharged via two new outfalls into Bayou Casotte. Bayou Casotte Energy would 

employ general stormwater BMPs including good housekeeping, preventative maintenance, visual 

inspections, spill prevention and response, and management of runoff. Specific measures would be 

included in the Industrial SWPPP for operations that is being prepared by Bayou Casotte Energy. In 

Section 4.2.1, we have included a recommendation for Bayou Casotte Energy to finalize the Industrial 

SWPPP in consultation with MDEQ prior to the start of construction. Bayou Casotte Energy would also 

be required to comply with the provisions of a NPDES Industrial Stormwater Permit, if issued by MDEQ, 

during operations at the proposed LNG terminal site. 

Bank Erosion 

Bank erosion could occur along the waterway between Petit Bois and Horn Islands used by LNG 

vessels as well as near and within the proposed terminal slip. Bank erosion could reduce bank stability 

and result in suspension of sediments, nutrients and contaminated media in Bayou Casotte and adjacent 

areas. Bank erosion could also directly result in a loss of habitat for vegetative species and some sessile 

organisms. In addition, bank erosion could result in localized increases in water column turbidity and 

associated potential impacts to fish and benthic species, as noted above. However, the potential for these 

effects should be limited since bank erosion is a relatively slow process and would therefore be unlikely 

to result in high turbidity loads. Because of the anticipated slow speed of the LNG marine traffic 

transiting the waterway and the distance from Petit Bois and Horn Islands to the transit channel, bank 

erosion from this source would not be considered to be significant. Further, it does not appear that the 

location, size, and shape of the proposed terminal slip would result in significantly modified flow 

velocities or cause increased erosion of adjacent channel banks. 

Propeller Wash 

The movement of large vessels (i.e., LNG carriers or crude oil tankers) has the potential to result 

in additional bank erosion, associated turbidity, and bottom substrate scour through creation of waves or 

wakes caused by propeller wash. The resulting turbidity and potential movement of bottom sediments 

could affect both fish and more sessile aquatic invertebrates. As described above, excessive turbidity can 

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result in both physiological and behavioral effects in fishes. In addition, movement of sediments due to 

propeller wash could result in shifting and covering of benthic habitats. Although temporary, movement 

of sediments along the bottom could result in more sessile organisms being covered. The potential for 

propeller wash induced Erosion within the proposed terminal slip would be minimized by armoring the 

walls and slopes of the slip with rock riprap overlaid on a geotextile fabric. Additionally, the proposed 

terminal site is located near the downstream end of an existing shipping channel that is already subject to 

the frequent passage of large vessels. The potential for excessive bank erosion induced by Project 

operations should therefore be minimal. 

Unanticipated Spills 

As discussed above, terrestrial and aquatic resources could be injured or suffer mortality due to 

accidental or intentional (i.e., terrorist activity) spills of fuel or other toxic substances. Bayou Casotte 

Energy would use training and engineering controls to minimize the potential for, and effect of, any 

inadvertent spills at the proposed terminal site during operations. Bayou Casotte Energy has already 

developed a SPCC Plan (see Appendix D). In Section 4.2.1, we have included a recommendation that 

Bayou Casotte Energy develop and finalize an operational SPCC Plan prior to the start of construction. 

This plan would identify measures to prevent and mitigated the effects of accidental spills during 

operations. Additional information on accidental spill prevention during operations is provided in 

Sections 4.2.1 and 4.3.1. 

Intake of Ballast Water and Cooling Water by LNG Vessels 

LNG carriers would take on ballast water to maintain stability (up to 15 million gallons per vessel 

offloading event) and use seawater for engine cooling (up to 42 million gallons per vessel offloading 

event) during berthing and while transiting the entire waterway from the territorial seas to the berthing 

facility. Given the location of the proposed terminal site near the mouth of Bayou Casotte, and the 

adjacent areas traversed including Mississippi Sound and the Gulf of Mexico, sufficient water is available 

to provide the quantities necessary for ballast and engine cooling operations. Ballast water would be 

taken on and retained during LNG offloading operations, but no ballast water would be discharged in 

Bayou Casotte, thereby preventing the potential discharge of exotic and invasive organisms. Water used 

for engine cooling would be quickly discharged, and the resulting increase in water temperature is 

expected to be minor. Further, Bayou Casotte and the entire transit waterway are active commercial 

shipping channels already subject to the withdrawal and discharge of vessel engine cooling water as 

discussed in Section 4.3.2, and that activity would not substantially affect water quality in the proposed 

Project area. 

There is potential for the entrainment of ichthyoplankton, including the larvae of managed 

species, from Bayou Casotte and the entire transit waterway associated with LNG carrier engine cooling 

water withdrawals. Entrainment of ichthyoplankton could result in mortality and reduced recruitment for 

fish and other aquatic species. Bayou Casotte Energy is currently in the process of consulting with 

NOAA Fisheries regarding the potential for ichthyoplankton impacts, but because these consultations are 

not yet complete, we recommend that: 

• Bayou Casotte Energy should complete consultations with NOAA Fisheries and MDMR 

regarding potential impacts to ichthyoplankton and aquatic resources resulting from 

the intake of ballast and engine cooling water, the discharge of cooling water, and all 

other activities that could result in withdrawal of marine surface waters (e.g., 

hydrostatic testing and maintenance dredging), and file the findings of these 

consultations with the Secretary, including any required or recommended measures to 

prevent or reduce impacts, prior to construction. 

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Invasive, Exotic Species 

In order to maintain a constant draft during the unloading operation, LNG carriers berthed at the 

proposed terminal slip would bring on ballast water during transfer of its LNG cargo and retain this 

ballast water until after the LNG ship departs Bayou Casotte. Although ballast water has been identified 

as a major pathway for the introduction and spread of exotic species, the absence of ballast water 

discharges while moored at the proposed terminal slip would limit the potential for import of exotic 

species. 

In addition to ballast water, there is a potential that exotic species could be imported on the hulls 

and exterior equipment of LNG carriers. If successful in establishing in the surrounding environment, 

exotic species can successfully out-compete native species, causing native species to decline. To combat 

this issue, the Coast Guard has developed responses to exotic/invasive organisms associated with foreign 

vessels. The Coast Guard 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 remove fouling organisms from hull, piping, and tanks on a regular 

basis and dispose of any removed substances in accordance with local, state, and federal regulations. Any 

LNG carriers visiting the proposed Project would comply with these practices. Therefore, we conclude 

that the introduction of non-indigenous attached organisms via ship hulls or ballast water would be 

unlikely to result in a significant alteration of the local biotic community. 

Effects of Slip Creation on Water Quality 

The recessed nature of the proposed terminal slip could cause stagnation, resulting in potential 

impacts to water quality within the slip and adjacent Bayou Casotte. These effects of stagnation could 

include increases in water temperature during warmer months and decreases in overall water quality (e.g., 

reduced dissolved oxygen levels). Fish and aquatic invertebrates typically have relatively rigid tolerances 

to fluctuations in temperature and dissolved oxygen. As oxygen levels begin to deplete in stagnant 

waters, organisms that are not able to relocate can suffer diminished survival, growth, and reproduction, 

or suffer mortality. If such localized water quality effects did occur, aquatic organisms capable of 

avoiding such conditions would do so; however, more sessile organisms could be affected by fluctuations 

in temperature and overall water quality. However, the potential for water quality impacts at the proposed 

terminal slip would be eliminated or effectively minimized through tidal flushing, regular LNG carrier, 

crude oil tanker, and tugboat traffic, and the generally shallow nature of the slip itself. Bayou Casotte 

Energy is in the process of consulting further with MDMR and MDEQ regarding the proposed slip design 

and potential effects on water quality. In Section 4.3.2 we have included a recommendation that Bayou 

Casotte Energy file the results of those consultations with the Commission prior to the start of 

construction.

Maintenance Dredging 

According to preliminary modeling, Bayou Casotte Energy estimates that maintenance dredging 

of the proposed terminal slip could generate up to 250,000 yd3

 of material per year during operations, as 

described in Section 2.7.1. Potential impacts to habitats and aquatic species due to dredging have been 

discussed in Section 4.5.2.2 above. In the DMMP, Bayou Casotte Energy has identified placement of 

maintenance dredge materials at the Pascagoula ODMDS as its primary disposal option. Bayou Casotte 

Energy has also indicated that it would consider placement of maintenance dredge materials at beneficial 

use sites, as well as coordination of maintenance dredging with the COE’s routine maintenance dredging 

of the Bayou Casotte channel. 

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As discussed previously in relation to initial dredging associated with construction of the 

proposed terminal slip, Bayou Casotte is an industrialized shipping channel that is already subject to 

routine maintenance dredging by the COE. Additionally, Bayou Casotte Energy is in the process of 

consulting with MDEQ, MDMR, COE, and NOAA Fisheries regarding the development of dredging 

BMPs and possible monitoring measures. Bayou Casotte Energy has also filed its Section 103 evaluation 

with the COE and is awaiting approval of its dredge disposal plan. With implementation of these 

measures and recommendations, it is not anticipated that maintenance dredging would result in significant 

effects to marine and estuarine habitats or species, especially given the existing turbid nature of Bayou 

Casotte. 

Increased Noise 

Increased vessel traffic would occur during operation of the proposed Project, resulting in 

additional noise in Bayou Casotte as well as the approaches to Bayou Casotte in the Gulf of Mexico. 

Traffic would increase from tug boats using the new slip and an estimated 170 LNG carrier vessels that 

would use the proposed LNG terminal annually. Although noise can affect fish behavior, it is difficult to 

determine the impact of anthropogenic noise in the marine environment (Stocker 2002). Altered behavior 

due to noise effects could change feeding habits and movement patterns, cause stress, and otherwise 

interfere with the normal physiology of fishes and aquatic organisms, thereby potentially reducing 

growth, reproduction, and survival. However, Bayou Casotte is an existing shipping channel already 

subject to maintenance dredging every three years by the COE, we conclude that fish and other mobile 

species would relocate to adjacent, unaffected areas for the duration of the disturbance. 

Impacts to Marine Soft Bottom and Water Column Habitats 

Bayou Casotte Energy proposes to dispose of sediments dredged from the slip during 

construction at the EPA’s permitted Pascagoula ODMDS. Bayou Casotte Energy’s results of its sampling 

analysis, filed with the COE, indicate that the chemical parameters are within acceptable limits for 

sediment disposal at the Pascagoula ODMDS or other beneficial use sites. 

The disposal of dredged sediments at the Pascagoula ODMDS was evaluated in an EIS prepared 

by the EPA (1991), in coordination with the U.S. Navy and COE as cooperating agencies. The EPA 

concluded that impacts associated with placement of the dredged materials in the ODMDS would be 

localized to the vicinity of the disposal site and that they “would not significantly alter the long-term 

productivity of the site.” Following disposal, monitoring of the ODMDS would include a bathymetric 

survey performed by Bayou Casotte Energy and sediment mapping conducted by EPA. The ODMDS site 

routinely accepts spoils from Bayou Casotte, and the site was designed for use by multiple entities 

including the adjacent Chevron Pascagoula Refinery (EPA 1991). 

For the reasons outlined above, we do not anticipate that disposal of sediments excavated from 

the proposed LNG terminal slip would result in significant adverse effects to marine soft bottom and 

water column habitats or species associated with those habitats. The Commission and Bayou Casotte 

Energy are proceeding under the assumption that sediments would be suitable for placement in the 

ODMDS. However, final agency approvals required pursuant to Section 103 of the MPRSA have not yet 

been obtained (see Section 4.2.2). 

4.5.3 Freshwater Resources 

Potential habitat for freshwater fisheries in the vicinity of the Casotte Landing Project includes 

several emergent wetlands and man-made ponds, drainage canals, and ditches. The vegetation within the 

emergent wetlands that would be affected in the project area is discussed in Section 4.4. Surface water is 

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generally only present for brief periods during the growing season in these wetlands and the water table 

usually lies well below the soil surface. Therefore, emergent wetlands in the project area are not 

anticipated to support freshwater fisheries. 

The proposed terminal site would impact two ponds, two canals, and 10 ditches; while the 

pipeline interconnects and nonjurisdictional facilities would cross three canals and five ditches (see 

Table 4.3.2-1). All of the onshore waterbodies contain water year-round with the exception of five 

ditches. Bayou Casotte Energy reported that only the striped mullet was identified within the waterbodies 

located at the proposed terminal site. Bayou Casotte Energy would implement its Procedures, as 

modified in this EIS, to minimize construction-related impacts on these waterbodies. 

4.5.4 Essential Fish Habitat 

The MSA requires that EFH be designated for species managed by NOAA Fisheries or regional 

Fishery Management Councils (FMC). EFH is defined as “those waters and substrate necessary to fish 

for spawning, breeding, feeding, or growth to maturity” (16 USC 1802(10)). EFH may include both 

water column and benthic habitats that support the different life stages of managed fishery resources. 

According to the Gulf of Mexico FMC, all estuarine and marine waters and substrates within the northern 

Gulf of Mexico, extending from the shoreline to the exclusive economic zone boundary, are considered 

EFH (GMFMC 1998). A variety of managed fish and shellfish species occur within this region, but EFH 

for 18 individual species and the “billfish and highly migratory species group” has the potential to occur 

within the proposed Project area. These species are listed in Table 4.5.2-2. 

The MSA requires NOAA Fisheries to minimize effects to EFH and managed species to the 

extent practicable and it requires federal agencies to consult with NOAA Fisheries regarding potential 

impacts resulting from projects under federal purview (NOAA 2006b). The FERC is the lead federal 

agency for the purposes of evaluating the proposed Project under NEPA. Therefore, the FERC requests 

that NOAA Fisheries consider the draft EIS as notification of the initiation of EFH consultation. 

Generally, the EFH consultation process includes the following steps: 

1. Notification – The action agency should clearly state the process being used for EFH 

consultations, such as incorporation of EFH consultation into the EIS, as is the case with 

the proposed Casotte Landing Project; 

2. EFH Assessment – The action agency should prepare an EFH Assessment that includes 

both identification of affected EFH and an assessment of potential impacts. Specifically, 

the EFH Assessment should include: a) 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 review of the EFH Assessment, NOAA 

Fisheries would provide recommendations to the action agency regarding measures that 

can be taken by that agency to conserve EFH; and 

4. Agency Response – The action agency must respond to NOAA Fisheries within 30 days 

of receiving NOAA Fisheries’ recommendations or the action agency may notify NOAA 

Fisheries that a full response to the conservation recommendations will be provided by a 

specified completion date agreeable to all parties. The response must include a 

description of measures proposed by the agency for avoiding, mitigating, or offsetting the 

impact of the activity on EFH. 

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On our behalf, Bayou Casotte Energy is in the process of consulting with NOAA Fisheries 

regarding conservation measures that would avoid, minimize, or mitigate for potential Project related 

impacts to EFH and managed species. As part of those consultations, representatives of Bayou Casotte 

Energy compiled baseline data on existing EFH resources that occur within the proposed project area. 

That information is provided in the EFH Assessment for the Casotte Landing Project, which is included 

as Appendix F of this EIS. An analysis of the cumulative impacts of the project on aquatic resources 

(including EFH) is presented in Section 4.13, and our assessment of the potential for Project effects on 

EFH is provided below. 

4.5.4.1 Conclusions of EFH Assessment 

The proposed Project was sited and designed to avoid and minimize potential impacts to EFH and 

other fish and wildlife resources. Additionally, Bayou Casotte Energy has proposed specific measures, as 

discussed in this section, to further minimize or mitigate for potential impacts. Impacts to onshore 

waterbodies and wetlands at the proposed terminal site would be permanent, but would be mitigated in 

consultation with the COE during the permitting process. Impacts to waterbodies and wetlands affected 

by the interconnects would be temporary, and wetlands would be restored in accordance with Bayou 

Casotte Energy’s Procedures, as modified in this EIS (see Section 4.3.2). Additional measures to 

minimize or mitigate for temporary wetland impacts may be required by the COE or MDMR during 

permitting. Soft bottom and water column habitats, in both the estuarine and marine environment, 

including the waterway transited by LNG vessels from the territorial seas to the berthing facility, would 

be disturbed by construction and operation of the proposed Project. However, these impacts would be 

minor and largely temporary. 

We conclude that the proposed Project would not result in significant adverse effects to EFH or 

managed species based on: 

• the previously disturbed and modified character of the potentially affected onshore 

waterbodies and wetlands, estuarine habitats of Bayou Casotte, and the Pascagoula ODMDS; 

• the measures to avoid and/or minimize impacts that have been proposed by Bayou Casotte 

Energy; 

• the conditions that the FERC has recommended in this EIS; and 

• the impact avoidance and minimization requirements that would be implemented as a result 

of other permitting and regulatory approvals that would be required for authorization of the 

proposed Project. 

However, because EFH consultations are not yet complete and because mitigation for those 

permanent impacts to EFH that would occur as a result of the proposed Project has not yet been agreed 

upon, we recommend that:

• Bayou Casotte Energy should finalize consultations with NOAA Fisheries, MDMR, and 

the COE to develop a plan for quantifying, if appropriate, and mitigating impacts to 

EFH and file that plan with the Secretary for review and written approval of the 

Director of OEP prior to construction. 

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4.6 THREATENED, ENDANGERED, AND OTHER SPECIAL STATUS SPECIES 

4.6.1 Federally Listed Threatened and Endangered Species 

Section 7 of the Endangered Species Act (ESA) requires each Federal agency to ensure that any 

action authorized, funded, or carried out by the agency does not jeopardize the continued existence of 

federally listed endangered or threatened species, or result in the destruction or adverse modification of 

the designated critical habitat for any federally listed species. The FERC, as lead agency in the review of 

the proposed Project, is required to consult with the FWS and/or NOAA Fisheries to determine whether 

federally listed or proposed species, or their designated critical habitat, may occur in the Project area, and 

to determine the proposed action’s potential effects on these species and critical habitats. For actions 

involving major construction activities with the potential to affect listed species or designated critical 

habitats, the FERC must report its findings to FWS and NOAA Fisheries in a Biological Assessment 

(BA). 

To assist the FERC in meeting our Section 7 requirements, Bayou Casotte Energy as a nonfederal representative, conducted informal consultation with the FWS, NOAA Fisheries, MDMR, and 

Mississippi Museum of Natural Science-Natural Heritage Program (MMNS-NHP). In addition, Bayou 

Casotte Energy reviewed endangered and threatened species related databases maintained by the FWS, 

MMNS-NHP, and NatureServe Explorer. Bayou Casotte Energy conducted field surveys of the proposed 

LNG terminal site and proposed pipeline interconnect routes in April 2005 and December 2005. No 

threatened or endangered species were observed during the surveys. 

We have reviewed the information submitted by Bayou Casotte Energy, and our analysis of the 

potential for Project-related effects to federally listed species and their designated critical habitats is 

provided in this EIS. To comply with Section 7 of the ESA, we request that NOAA Fisheries and FWS 

consider this EIS as our BA for the proposed Project and concur with the determinations provided herein. 

Habitats that occur in the proposed Project area include shallow marine environments, wetlands, 

onshore waterbodies, and uplands (see Sections 4.3, 4.4, and 4.5). Most of the proposed LNG terminal 

site and proposed pipeline interconnect routes are generally highly disturbed and industrialized. These 

areas would provide limited or no habitat for federally listed species. Bayou Casotte is an active shipping 

channel, and the estuarine habitats at the proposed terminal site are periodically disturbed by routine 

maintenance dredging performed by the COE. Offshore environments that would be affected during 

construction and operation have the potential to support transient endangered and threatened species. 

Based on consultation with the FWS, NOAA Fisheries, MMNS-NHP, and MDMR and review of 

existing records, 26 federally listed endangered and threatened species were identified that could 

potentially occur in the vicinity of the proposed Project or along the LNG ship transit route within the 

waters of the Gulf of Mexico. We conclude that 11 of these species do not occur in the Project area or 

would not be affected by construction and operation of the proposed Project based on the results of field 

surveys, initial agency consultations, and review of existing information. These include several terrestrial 

and avian species, which clearly lack suitable habitat or a significant potential for negative interaction 

with the proposed Project. These species, their status, preferred habitats, potential for occurrence, and our 

assessment of potential Project effects are discussed in Table 4.6.1-1. Because these species would not be 

adversely affected by the proposed Project, they have been eliminated from further consideration in our 

analysis. 

Surveys performed by Bayou Casotte Energy did not identify any high quality habitat for federal 

or state protected species at the proposed terminal site or along the proposed pipeline interconnect routes. 

However, consultations with the FWS and NOAA Fisheries indicate that the proposed Project could 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 4.6.1-1 

Federally Listed Species Eliminated From Further Consideration for the Casotte Landing LNG Proje

Species 

Federal/ 

State 

Status 

Project Effect Habitat Potential for Oc

Plants Louisiana quillwort (Isoetes louisianensis)

T/S2 No effect. Sand and gravel bars on small- to 

medium-sized streams. 

Suitable freshwater h

Reptiles Alabama redbelly turtle (Pseudemys alabamensis)

E/S1 No effect. Quiet backwaters with dense 

submerged vegetation, in water 3 – 6 feet deep. Also found in river channels. Uses sand spoil banks and natural levees for nesting. 

Occurs in brackish wonly as a straggler. PHeritage Program, thin an apparent gap in The species was not surveys. 

Eastern indigo snake (Drymarchon corais couperi)

T/S1 No effect. Xeric sandhills, cabbage palm 

hammocks, and near ponds, streams, and swamps often associated with gopher tortoise burrows. Requires large areas of habitat. 

Suitable habitat does Project site. 

Gopher tortoise (Gopherus polyphemus)

T/S2 No effect. Well-drained, sandy soils in transitional 

areas with a pine overstory, an open understory, and a grass and forb groundcover. 

Suitable habitat does Project site. 

Yellow-blotched map turtle (Graptemys flavimaculata) 

T/S2 No effect. Riverine habitat with moderate current, 

sand, clay, or rocky bottom, sand bars, limestone ledges, tangled tree roots, and logs. Also utilizes ponds and oxbow lakes. 

Suitable habitat does Project site. The speduring field surveys. 

Birds Piping plover (Charadrius melodus)

T/SZN No effect. Sandy upper beaches with grass tufts, 

lightly vegetated shores, and islands of shallow lakes, ponds, and rivers. Nonbreeding habitat includes algal flats, sand flats, and mud flats. 

Suitable, high quality the Project area. FWhabitat occurs within proposed Project site

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 4.6.1-1 (continued) 

Federally Listed Species Eliminated From Further Consideration for the Casotte Landing LNG Proje

Species 

Federal/ 

State 

Status 

Project Effect Habitat Potential for O

Birds (continued) Mississippi sandhill crane (Grus canadensis pulla)

E/S1 No effect. Wetlands bordering pine forests, 

swamp edges, and open savannas. 

Suitable nesting haproposed Project shabitat may be prenot observed durin

Red-cockaded woodpecker (Picoides borealis) 

E/S1 No effect. Savanna with scattered overstory of 

large pines and dense groundcover of grass, forb, and shrub. Also inhabits open, mature pine woodlands. 

Suitable habitat doproposed Project s

Mammals Louisiana black bear (Ursus americanus luteolus) 

T/S1 No effect. Bottomland forests with diverse food 

resources; hollow trees and brush piles. Prefers remote areas with little or no human contact. 

Suitable habitat doproposed Project s

Invertebrates Fat pocketbook (Potamilus capax) 

E/S1 No effect. Slow-flowing portions of large, 

freshwater rivers. Sand, mud, and fine gravel substrates. 

Suitable freshwatethe proposed Proje

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 4.6.1-1 (continued) 

Federally Listed Species Eliminated From Further Consideration for the Casotte Landing LNG Proje

Species 

Federal/ 

State 

Status 

Project Effect Habitat Potential for Oc

Fish Smalltooth sawfish (Pristis pectinata) 

E/NS No effect. Shallow coastal and estuarine waters, 

often near river mouths and large embayments. 

According to NOAA juvenile habitats do area, and abundancof harm is considere

_______________ Notes:  E = Endangered  T = Threatened  S1 — Critically imperiled in Mississippi because of extreme rarity (5 or fewer occurrences or very few remaining individuals or acres) or because of s

vulnerable to extirpation. 

 S2 — Imperiled in Mississippi because of rarity (6 to 20 occurrences or few remaining individuals or acres) or because of some factor(s) making it vu

 SZ — Zero occurrences in the state. Not of practical conservation concern in the state, because there are no definable occurrences, although the ta

regularly in the state. 

Breeding Status: (Applicable to migratory species, mainly birds, but also includes sea turtles, some fish, and some insects).  B — Breeding Status  N — Non-breeding Status Sources: Mississippi Museum of Natural Science – Natural Heritage Program (including letter dated March 31, 2005)  NOAA Fisheries (including letter dated June 8, 2005) 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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encompass habitat for or involve interaction with 15 federally listed endangered or threatened species. 

These species include seven mammals (sperm whale, blue whale, sei whale, fin whale, humpback whale, 

North Atlantic right whale, and the Florida manatee); one fish (Gulf sturgeon); five reptiles (hawksbill sea 

turtle, green sea turtle, Kemp’s ridley sea turtle, leatherback sea turtle, and loggerhead sea turtle); and two 

birds (bald eagle and brown pelican). These species, their status, habitat, potential for occurrence, and 

our assessment of potential Project effects are listed in Table 4.6.1-2 and discussed in more detail below. 

Additional information regarding LNG shipping incidents and their potential impacts along the transit 

corridor is provided in Section 4.12.5.3 

4.6.1.1 Mammals 

Whales 

Offshore environments that would be traversed by LNG marine traffic associated with operation 

of the proposed LNG terminal may provide potential movement corridors for the blue, fin, humpback, 

North Atlantic right, sei, and sperm whales. Whales are highly transient in deep, offshore waters. It is 

unlikely that LNG carrier traffic in offshore areas would affect such highly mobile species. Furthermore, 

existing shipping traffic already uses these shipping corridors. Bayou Casotte Energy has agreed to adopt 

and comply with NOAA Fisheries’ Vessel Strike Avoidance and Injured/Dead Protected Species 

Reporting policy to minimize the risk to whales from contact with shipping. These procedures include: 

• use of a Gulf of Mexico reference guide that includes and helps identify the 28 species of 

whales and dolphins, five species of sea turtles, and the one species of manatee that might be 

encountered in the Gulf of Mexico Outer Continental Shelf; 

• maintain a vigilant watch for marine mammals and sea turtles and slow down or stop their 

vessel to avoid striking protected species; 

• maintain a distance of 300 feet or greater between the vessel and whales; 

• attempt to maintain a distance of 150 feet or greater between the vessel and sea turtles or 

small cetaceans; 

• attempt to remain parallel to the animal’s course and avoid excessive speed or abrupt changes 

in direction when protected species are sighted in the area; 

• reduce vessel speed to 10 knots or less when mother/calf pairs, pods, or large assemblages of 

cetaceans are observed near an underway vessel; 

• reduce speed and shift the engine to neutral when protected species are sighted in the vessel’s 

path or in close proximity to a moving vessel; and 

• report sightings of any injured or dead protected species (marine mammals and sea turtles) 

immediately to the Marine Mammal and Sea Turtle Stranding Hotline or the Marine Mammal 

Stranding Network. 

Of the federally listed whale species considered in our analysis, no resident stock for five of these 

species (blue, sei, fin, humpback, and North Atlantic right whales) occurs in the Gulf of Mexico. NOAA 

Fisheries indicated in its letter dated June 8, 2005, that the “potential for interaction between any of the 

proposed Project’s activities and these whale species is extremely low.” We concur with this assessment 

and conclude that the proposed Project would have no effect on these species. The sperm whale is the 

only whale species that occurs in the Gulf of Mexico with enough frequency to be potentially affected by 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 4.6.1-2 

Federally Listed Species Potentially Affected in the Casotte Landing LNG Project Area 

Species 

Federal/ 

State 

Status 

Project Effect Habitat Potential 

Mammals Blue whale (Balaenoptera musculus) 

E/NS No effect. Open ocean; cold, mostly pelagic 

waters. Calves are born in warmer waters of lower latitudes. 

According to NOAA Firesident stock in the Gpotential for interaction is extremely low. 

Fin whale (Balaenoptera physalus) 

E/NS No effect. Pelagic water, usually 25 miles or more 

from shore. 

According to NOAA Firesident stock in the Gpotential for interaction is extremely low. 

Humpback whale (Megaptera novaengliae) 

E/NS No effect. Pelagic and coastal waters According to NOAA Fi

resident stock in the Gpotential for interaction is extremely low. 

North Atlantic right whale (Eubalaena glacialis) 

E/NS No effect. Pelagic and coastal waters According to NOAA Fi

resident stock in the Gpotential for interaction is extremely low. 

Sei whale (Balaenoptera borealis) 

E/NS No effect. Offshore waters in deep water. According to NOAA Fi

resident stock in the Gpotential for interaction is extremely low. 

Sperm whale (Physeter macrocephalus) 

E/NS Not likely to 

adversely effect. 

Pelagic offshore, deep waters More common in the G

whale species but, accthe potential for interaProject is extremely lo

Florida manatee (Trichechus manatus) 

E/SZ Not likely to 

adversely affect. 

Shallow coastal waters, estuaries, bays, rivers, and lakes. Usually associated with freshwater sources. 

May occur in estuarine adjacent to the propos

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 4.6.1-2 (continued) 

Federally Listed Species Potentially Affected in the Casotte Landing LNG Project Area 

Species 

Federal/ 

State 

Status 

Project Effect Habitat Potential 

Fish Gulf sturgeon (Acipenser oxyrinchus desotoi) 

T/S1 Not likely to 

adversely affect. 

Marine and estuarine in fall and winter, migrates to upper rivers to spawn in spring and summer. Riverine habitat includes hard clay bottom, rubble, 

gravel, and rock ledges and shelves. 

May occur in estuarine adjacent to the propos

Reptiles Green sea turtle (Chelonia mydas) 

T/SZN Not likely to 

adversely affect. 

Feeds in shallow, low-energy water with abundant submerged vegetation. Rests on rocky outcrops and coral reefs. Nests on coarse- to fine-sand beaches; prefers high energy beaches with deep sand. 

May occur in estuarinesand beach areas adjaProject site. 

Hawksbill sea turtle (Eretmochelys imbricata)

E/NS Not likely to 

adversely affect. 

Shallow coastal waters with rocky bottoms, coral reefs, and mangrovebordered bays and estuaries. Nests on undisturbed, low-energy, deep-sand beaches. 

May occur in estuarinesand beach areas adjaProject site. 

Kemp’s ridleys sea turtle (Lepidochelys kempii) 

E/S1N Not likely to 

adversely affect. 

Shallow coastal and estuarine waters. Nests on elevated dunes. 

May occur in estuarinesand beach areas adjaProject site. 

Leatherback sea turtle (Dermochelys coriacea) 

E/NS Not likely to 

adversely affect. 

Open ocean, as well as gulfs, bays, and estuaries. Nests on sandy beaches near deep, open ocean with no fringing reef. 

May occur in estuarinesand beach areas adjaProject site. 

Loggerhead sea turtle (Caretta caretta) 

T/S1B, SZN 

Not likely to adversely affect. 

Open ocean, as well as bays, estuaries, lagoons, creaks, and mouths of rivers. Nests on sandy, high-energy, steeply sloped beaches on barrier islands. 

May occur in estuarinesand beach areas adjaProject site. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 4.6.1-2 (continued) 

Federally Listed Species Potentially Affected in the Casotte Landing LNG Project Area 

Species 

Federal/ 

State 

Status 

Project Effect Habitat Potential 

Birds Bald eagle (Haliaeetus leucocephalus) 

T/S1B, S2N 

Not likely to adversely affect. 

Areas within 2.5 miles of coastal areas, bays, rivers, lakes, or other bodies of water with food sources including fish, waterfowl, and seabirds. 

Suitable nesting habitaproposed Project site, provide some foraging not observed during fi

Brown pelican (Pelecanus occidentalis) 

T/S1N Not likely to 

adversely affect. 

Coastal shallow estuaries, sand spits, offshore sand bars, and islets. Requires dry roosting sites. 

Marginal, low quality hproposed Project site, observed during field s

_______________ Notes:  E = Endangered  T = Threatened  S1 — Critically imperiled in Mississippi because of extreme rarity (5 or fewer occurrences or very few remaining individuals or acres) or because of 

vulnerable to extirpation. 

 S2 — Imperiled in Mississippi because of rarity (6 to 20 occurrences or few remaining individuals or acres) or because of some factor(s) making it v SZ — Zero occurrences in the state. Not of practical conservation concern in the state, because there are no definable occurrences, although the 

regularly in the state. 

Breeding Status: (Applicable to migratory species, mainly birds, but also includes sea turtles, some fish, and some insects).  B — Breeding Status  N — Non-breeding Status Sources: Mississippi Museum of Natural Science – Natural Heritage Program (including letter dated March 31, 2005)  NOAA Fisheries (including letter dated June 8, 2005) 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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the proposed Project. Even so, the probability of whales encountering LNG marine traffic in the open 

ocean is inherently low due to the species’ ability to avoid on-coming vessels coupled with their overall 

rarity. 

For LNG ship operation in the open Gulf of Mexico there is a possibility that fuel used for vessel 

propulsion or auxiliary/emergency generators could spill or leak. Each vessel would maintain a 

Shipboard Oil Pollution Emergency Plan as required by international convention. Additional information 

regarding LNG shipping incidents and their potential impacts along the transit corridor is provided in 

Section 4.12.5.3. 

Given the low potential for interaction with the proposed Project and the measures that would be 

implemented to avoid or minimize impacts, as described above, we conclude that the proposed Project 

would not be likely to adversely affect sperm whales. 

Florida Manatee 

The Florida manatee is a large, slow-moving marine mammal found in lagoons, rivers, estuaries, 

and coastal areas along the east and west coasts of Florida. It feeds primarily on submergent, emergent, 

and floating vegetation. During colder winter months, manatees move south, and during warmer summer 

months they move north and west in the Gulf of Mexico. Its range extends as far west on the Gulf of 

Mexico coast as Louisiana. 

Collisions with powerboats or outboard propellers pose a significant threat to manatees. 

Watercraft collisions account for approximately 25 percent of all manatee deaths (FWS 2006e). Boats 

traveling faster than 15 mph are capable of injuring or killing a manatee. Manatees can also be injured or 

entangled in locks, flood control structures, and fishing nets. Construction of the proposed LNG terminal 

and the LNG carrier traffic associated with its operation has the potential to affect the Florida manatee. 

However, Bayou Casotte Energy has agreed to adopt and comply with NOAA Fisheries’ Vessel Strike 

Avoidance and Injured/Dead Protected Species Reporting policy and station a wildlife observer to watch 

for manatees and other sensitive species during construction activities, including dredging operations, to 

minimize the risk to manatees. Given these measures, and considering that submerged aquatic vegetation, 

a preferred food source, is not found in the immediate vicinity of the proposed Project, we conclude that 

the proposed Project would be not likely to adversely affect the Florida manatee. Potential cryogenic and 

thermal impacts along the waterway are discussed in greater detail in Section 4.12.5. 

4.6.1.2 Fish 

Gulf sturgeon 

The Gulf sturgeon is a large anadromous fish that occurs in the Gulf of Mexico and several river 

systems of southeastern United States. Its habitat includes riverine, estuarine, and nearshore marine 

environments. Juvenile Gulf sturgeon typically spend their first two years in the riverine environment 

before migrating to the ocean. Almost all feeding and growth occurs during winter months spent in 

estuarine and nearshore marine environments. In March and April, mature Gulf sturgeon migrate upriver, 

often over 100 miles, to freshwater spawning sites. After spawning, they return to the Gulf of Mexico in 

late fall to spend the winter feeding on benthic invertebrates and small fishes. 

Critical Habitat

The Gulf sturgeon was federally listed as threatened in 1991, and critical habitat was designated 

in 2003. The southwest corner of the proposed LNG terminal site overlaps a portion of this designated 

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critical habitat (Critical Habitat Unit 8) which includes several areas in the northern Gulf of Mexico 

including Mississippi Sound adjacent to Jackson County, Mississippi and the proposed Project. The FWS 

and NOAA Fisheries identified seven primary constituent elements, defined as those physical and 

biological features that are essential to the conversation of the species and that may require special 

management considerations or protection, for the critical habitat of Gulf sturgeon. These primary 

constituent elements include: 

• abundant food items for juvenile and adult life stages, primarily including detritus, aquatic 

insects, worms, mollusks, polychaetes, and other benthic organisms in riverine, estuarine, and 

marine environments; 

• riverine spawning sites with suitable substrates for egg deposition and development, mostly 

hard substrates; 

• riverine aggregation areas, typically in deep holes used for resting, holding, or staging; 

• an adequate flow regime to provide a suitable environment for all life stages in the riverine 

environment; 

• water quality, including turbidity, dissolved oxygen, and other parameters; 

• sediment quality, including texture and other characteristics; and 

• safe and unobstructed migratory pathways. 

Potential Impacts to Primary Constituent Elements of Critical Habitat

The proposed Project would not affect any known Gulf sturgeon spawning sites or riverine 

resting, holding, or staging areas, nor would freshwater flow regimes be affected. Additionally, neither 

construction nor operation of the proposed Project would result in obstruction of migratory pathways, 

should they occur in the vicinity of Bayou Casotte. There is potential for impacts to abundant food items, 

water quality, and sediment quality resulting from construction and operations of the proposed Project 

and these primary constituent elements are discussed in more detail below. 

The proposed Project would affect approximately 6.3 acres of non-vegetated, estuarine soft 

sediments during construction dredging. Maintenance dredging of sediments within the newly 

constructed slip would also be required during operations. Dredging and excavation of the proposed 

marine slip would create approximately 49 acres of additional soft-bottom benthic habitat that could also 

potentially be used for foraging. As discussed in Section 4.5.2 numerous species of mollusks, 

polychaetes, and other benthic organisms, which could serve as prey items for juvenile and adult Gulf 

sturgeon, occur in this area and could be affected by the proposed Project. However, this area is already 

routinely dredged approximately every three years by the COE, resulting in a benthic community 

conditioned to periodic disturbance and largely comprised of opportunistic species that would soon recolonize disturbed habitats. 

Similarly, sediment texture and quality in Bayou Casotte would not be appreciably altered by 

dredging during construction or operations because it is already routinely disturbed. Contaminated soils 

and sediments would be identified and removed from the terminal site prior to excavation and dredging, 

thereby preventing the potential mobilization of toxic constituents into the estuary. Construction and 

maintenance dredging would be performed with clamshell or dragline dredges to minimize the risk to 

Gulf sturgeon, rather than hopper dredges, which are known to injure Gulf sturgeon. Additionally, Bayou 

Casotte Energy proposes to dispose of all non-contaminated, dredged sediments at the existing 

Pascagoula ODMDS, which is located outside of designated Gulf sturgeon critical habitat. That site has 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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already been approved for disposal of dredge spoils from Bayou Casotte channel (USEPA 1991), and no 

significant adverse effects would be anticipated with its use as proposed. 

Given the condition of the estuarine sediments, the benthic community at Bayou Casotte, and the 

availability of expansive, less disturbed estuarine habitat in Mississippi Sound, we conclude that any 

impacts resulting from the proposed Project would be temporary and minor and would not result in 

significant impacts to Gulf sturgeon food availability or sediment quality or texture. 

The proposed Project could potentially affect water quality in Bayou Casotte in a number of 

ways, as discussed in Section 4.3.2. Potential effects could result from stormwater runoff from the 

terminal site during construction and operations, hydrostatic testing, accidental spills, bank erosion caused 

by waves or vessel propeller wash, and intake/discharge of ballast water and cooling water by vessels at 

the terminal and along the entire transit waterway. The potential for effects to water quality within Gulf 

sturgeon critical habitat from these activities or sources is low, given the measures and plans that would 

be implemented by Bayou Casotte Energy, ongoing Agency consultations and resulting permit 

requirements, and the conditions that Commission staff have recommended in Section 4.3.2. Two other 

potential causes of effects to water quality, operation of the proposed slip and sedimentation and turbidity 

during construction and maintenance dredging, have relatively greater potential to affect Gulf sturgeon 

critical habitat and are discussed in more detail below. 

Impacts to water quality such as depressed levels of dissolved oxygen could occur within the 

proposed terminal slip and adjacent Bayou Casotte due to the recessed nature of the slip and the potential 

for stagnation. However, the potential for these impacts would be eliminated or effectively minimized 

through tidal flushing, regular ingress and egress of LNG carrier and tug traffic, and the generally shallow 

nature of the slip itself. Additionally, Bayou Casotte Energy is in the process of consulting with MDMR 

and MDEQ regarding the proposed slip and its possible effects on water quality. In order that these 

consultations may be completed in a timely manner, we have included a recommendation in Section 4.3.2 

that Bayou Casotte Energy complete the consultations and report on any required mitigation or 

monitoring measures prior to the start of construction. 

Bayou Casotte Energy modeled the potential for suspension of sediment associated with dredging 

of the slip using the COE’s DREDGE model. The analysis indicated that maximum predicted levels of 

TSS would be 19.9 mg/l at a distance of approximately 30 feet from the dredging activity, with 

concentrations of TSS dropping at distances further away from the activity. The estimated levels of TSS 

associated with the proposed Project are similar to or below existing, background levels for Bayou 

Casotte. Bayou Casotte is a turbid estuary under existing conditions, with ambient TSS levels of 

approximately 36 mg/l to 55 mg/l and turbidity levels of approximately 15 to 20 NTUs. Potential impacts 

to water quality within Gulf sturgeon critical habitat would be small given the relatively low levels of 

TSS that would be generated and in consideration that the area is already routinely subjected to periodic 

maintenance dredging (and suspension of sediments into the water column) for the shipping channel. 

Bayou Casotte Energy has included BMPs for dredging in its Joint Application to the COE 

(July 27, 2006) which included a dredging monitoring plan (see Appendix E). Final agency approval for 

the plan has not been received. 

Conclusions Regarding Gulf Sturgeon

Given the existing industrial character of Bayou Casotte, the anticipated effects of the proposed 

Project, including the mitigation measures proposed by Bayou Casotte Energy, we conclude that 

construction and operation of the proposed Project would not be likely to adversely affect Gulf sturgeon 

or the primary constituent elements of its designated critical habitat. 

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4.6.1.3 Reptiles 

Marine Sea Turtles 

Sea turtles occupy a variety of habitats, including open ocean, estuarine areas, and coral reefs. 

Nesting typically occurs on high-energy sand beaches, and sea turtles are not known to nest at Bayou 

Casotte or in the immediate vicinity of the proposed Project. Human development and artificial 

illumination can deter or disorient nesting sea turtles and hatchlings. As the MMNS-NHP indicated in its 

letter dated March 31, 2005, collision and propeller injuries from commercial fishing, recreational 

boating, and shipping are common. As described previously, Bayou Casotte Energy has agreed to adopt 

and comply with NOAA Fisheries’ Vessel Strike Avoidance and Injured/Dead Protected Species 

Reporting policy to minimize the risk to sea turtles from collisions with vessels. 

The green and loggerhead sea turtles are federally listed as threatened by the FWS. The 

hawksbill, Kemp’s ridley, and leatherback sea turtles are federally listed as endangered by the FWS. The 

MMNR-MNHP stated in their Project correspondence dated March 31, 2006 that the green, hawksbill, 

and leatherback sea turtles should not be affected by the proposed Project in inshore waters due to the 

rarity of their occurrence in the vicinity of the terminal site. The Kemp’s ridley sea turtle, however, 

regularly uses shallow nearshore waters during certain seasons. The loggerhead sea turtle may also 

occasionally use shallow nearshore waters. Increased vessel traffic associated with the proposed LNG 

terminal may affect the leatherback, Kemp’s ridley, and loggerhead sea turtles farther offshore, as they 

regularly occur in the inter-island channels that would be traversed by LNG marine traffic. However, 

impacts from Project related vessel traffic would be minimized through implementation of NOAA 

Fisheries’ Vessel Strike Avoidance and Injured/Dead Protected Species Reporting policy. Bayou Casotte 

Energy would also station a wildlife observer to watch for sea turtles during construction activities, 

including all dredging operations, further reducing the potential for impacts from vessels or mechanical 

dredging. 

As discussed in detail in Section 4.5.2, Bayou Casotte Energy proposes to install approximately 

265 pilings during construction of the marine berthing and unloading facilities. The piles would be 

approximately 100 to 140 feet long, with a diameter of 16 to 48 inches. They would be installed using a 

barge-mounted crane and various methods, including impact driving. In some cases, driving steel piles 

can generate noise and intense underwater sound pressure waves that can adversely affect nearby marine 

organisms. Based on consultations with NOAA Fisheries, Bayou Casotte Energy will adopt NOAA 

Fisheries Pile-Driving Harm Avoidance and Listed Species / Critical Habitat and Vessel Impacts

guidelines (November 7, 2005). These guidelines would constitute Bayou Casotte Energy’s pile driving 

plan. 

For LNG ship operation in the open Gulf of Mexico there is a possibility that fuel used for vessel 

propulsion or auxiliary/emergency generators could spill or leak. Each vessel would maintain a 

Shipboard Oil Pollution Emergency Plan as required by international convention. In addition, should this 

project be approved, Bayou Casotte Energy would prepare an SPCC Plan for operation of the project that 

would include procedures to prevent and mitigate accidental releases of oil, gas, lubricants, or hazardous 

materials (see Sections 4.2.1.7 and 4.3.1.4). Additional information regarding LNG shipping incidents 

and their potential impacts along the transit corridor is provided in Section 4.12.5.3. With the 

implementation of these measures, the low likelihood and limited volume of fuel spills in the vicinity of 

the transit route, coupled with the overall rarity of sea turtles, minimizes the potential for impacts on sea 

turtles. 

Given the lack of sea turtle nesting habitat at the proposed Project location and the 

implementation of Bayou Casotte Energy’s SPCC Plan, the Strike Avoidance Procedures, and the 

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proposed mitigation measures related to pile driving, we conclude that the proposed Project would not be 

likely to adversely affect marine sea turtles. 

4.6.1.4 Birds 

Bald Eagle 

The bald eagle is the second largest North American bird of prey with an average 7-foot 

wingspan. It has a distinctive white head and white tail offset against a dark brown body and wings in 

adult birds. The current range of the bald eagle includes all of the conterminous United States and it is 

especially common in areas with large expanses of aquatic habitat (FWS 2006a). Bald eagles that nest in 

southern latitudes frequently move northward in late spring and early summer, often summering as far 

north as Canada. Most eagles that breed at northern latitudes migrate southward during winter, or to 

coastal areas where waters remain unfrozen. Migrants frequently concentrate in large numbers at sites 

where food is abundant and they often roost together communally (FWS 2006b). Bald eagles are 

opportunistic foragers and diet varies across the range based on prey species available. They prefer fish, 

but will eat a great variety of mammals, amphibians, crustaceans, and birds, including many species of 

waterfowl (FWS 2006a). 

Bald eagles are most vulnerable during the first 12 weeks of the nesting cycle in which courtship, 

nest building, egg laying, incubation, and brooding occur. Nests are typically built high in tall trees or 

more rarely, on cliffs. Disturbance during this critical period may lead to nest abandonment, cracked and 

chilled eggs, and exposure of small young to the elements (FWS 2006b). Project activities near a nest late 

in the nesting cycle may also cause flightless young birds to prematurely leave nests, thus reducing their 

chance of survival. 

Bayou Casotte Energy conducted field investigations of the project area during April and 

December 2005. These surveys were conducted at the proposed LNG terminal and along the pipeline 

interconnect route. Suitable nesting habitat is not present on site, and no eagle nests were observed in the 

project area during these surveys. However, because the waters of the Mississippi Sound may provide 

foraging habitat for bald eagles, we have recommended that Bayou Casotte Energy consult with the FWS 

and conduct additional surveys, as necessary, if construction has not begun within 1 year from the date of 

issuance of the FERC approval (see Section 4.6.3). 

 Construction activities, including dredging and dredged material placement, may have a 

temporary impact on foraging habitat. Increases in noise, traffic, and lighting levels could also 

temporarily affect bald eagle foraging habits, potentially increasing stress to this species. However, given 

the high mobility of the bald eagle, the lack of nesting habitat at the proposed Project location, and the 

abundance of foraging habitat in the vicinity of the Project area, we conclude that the proposed Project 

would not be likely to adversely affect bald eagles. 

Brown Pelican 

The adult brown pelican is a large dark gray-brown water bird with white about the head and 

neck. Immatures are gray-brown above and on the neck, with white underparts. This species can reach 

up to 8 pounds and larger individuals have a wing spread of over 7 feet. Brown pelicans forage in 

shallow estuarine and inshore waters for fishes, especially menhaden, mullet, sardines, pinfish, and 

anchovies (FWS 2006c). 

The brown pelican has a large range extending from North America to South America. The 

eastern brown pelican (Pelecanus occidentalis carolinensis) occurs in North Carolina, South Carolina, 

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Florida, Louisiana, Mississippi, Texas, and in the Barrier Islands. Habitat of the brown pelican is mainly 

coastal and these birds are rarely seen inland or far out at sea. They typically feed in shallow estuarine 

waters less than 40 miles from shore. Pelicans make extensive use of sand spits, offshore sand bars, and 

islets. Dry roosting sites are essential and some roosting sites eventually may become nesting areas. 

Nests are usually located on coastal islands that are free of most predators (such as raccoons) and human 

disturbance, and are located on the ground or in small bushes and trees. Pelicans may shift between 

different breeding sites in response to changing food supply distributions and to erosion and flooding of 

nesting sites (FWS 2006c). 

Brown pelican populations are extremely vulnerable to chemical/pesticide pollution, disturbance 

of nesting birds by humans, declining food sources, and increased turbidity. Human disturbance not only 

disrupts reproductive success but may affect distribution patterns and age structure of pelicans using 

roosting sites. Habitat degradation affects both roosting and nesting patterns (FWS 2006c). 

The field surveys found that the project area does not contain suitable habitat for nesting, but may 

contain potential loafing habitat onshore and foraging habitat offshore. Because the project area may 

contain loafing and foraging habitat, we have recommended that Bayou Casotte Energy consult with the 

FWS and conduct additional surveys, as necessary, if construction has not begun within 1 year from the 

date of issuance of the FERC approval (see Section 4.6.3). 

Although construction activities, including dredging, may have a temporary impact on loafing 

and foraging habitat, the brown pelican is highly mobile and suitable habitat within the Grand Bay 

National Estuarine Research Reserve would provide ample habitat for any displaced individuals. 

Operation of the proposed project would result in an increase in marine traffic; however, because of the 

existing levels of marine traffic within the port, no impacts on brown pelicans are anticipated. 

Therefore, due to the high mobility of the brown pelican, the lack of nesting habitat at the 

proposed Project location, and the abundance of foraging habitat in the vicinity of the Project area, we 

conclude that the proposed Project would not be likely to adversely affect brown pelicans. 

4.6.2 Other Special Status Species 

4.6.2.1 State Listed Threatened and Endangered Species 

We initially identified 21 state listed endangered or threatened species that are not federally listed 

and which may occur in the Project area. Mississippi does not provide legal protection for state listed 

plants. Fifteen of the 21 species initially identified have been eliminated from further discussion based on 

a lack of suitable habitat at the proposed Project site or due to the highly transient nature of the species. 

Field surveys conducted in April 2005 and December 2005 identified possible habitat for several state 

listed endangered and threatened species. These species and their status, preferred habitat, potential for 

occurrence, and our assessment of potential Project effect are discussed in Table 4.6.2-1. 

We identified six state listed species that could potentially be affected by the proposed Project 

based on known distribution and evaluation of habitat in the Project vicinity. These species, their status, 

potential for occurrence, and Project effects are listed in Table 4.6.2-2. Suitable habitat may exist at the 

proposed Project site for the following six state listed species: Gulf salt marsh snake, Mississippi 

diamondback terrapin, American white pelican, gull-billed tern, least tern, and royal tern. However, due 

to the existence of low quality habitat on-site, the availability of higher quality and suitable habitats 

nearby, general species mobility and ability to avoid disturbance, and because the state listed species were 

not observed in field surveys, we conclude that the proposed Project would not be likely to adversely 

affect these species. 

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TABLE 4.6.2-1 

State Listed Species Eliminated From Further Consideration for the Casotte Landing LNG Projec

Species State Status Project Effect Habitat Potential 

Invertebrates Burris’ burrowing crawfish (Fallicambarus burrisi) 

S2 No effect. Pitcher plant bogs. Suitable habitat does 

Project site. 

Least crayfish (Cambarellus diminutus)

S2 No effect. Small to moderate, vegetated 

blackwater streams in pine woods. 

Suitable habitat does Project site. 

Mobile crayfish (Procambarus lecontei)

S2 No effect. Temporary, freshwater, lentic bodies of 

water. 

Suitable habitat does Project site. 

Southern hickorynut (Obovaria jacksoniana)

S2 No effect. Medium-sized gravel in freshwater with 

slow to moderate current. 

Suitable habitat does Project site. 

Speckled burrowing crayfish (Fallicambarus danielae)

S2 No effect. In or around pitcher plant bogs. Suitable habitat does 

Project site. 

Spiny-tailed crayfish (Procambarus fitzpatricki) 

S2 No effect. Burrows in sandy soil with high water 

table (freshwater). 

Suitable habitat does Project site. 

Birds Bewick’s wren (Thryomanes bewickii) 

S2, S3B, SZN 

No effect. Brushy areas; thickets and scrub in 

open country; riparian woodland; and chaparral. 

Suitable habitat does Project site. 

Black rail (Laterallus jamaicensis) 

S2N Not likely to 

adversely affect. 

Salt, brackish, and freshwater marshes, pond borders, wet meadows, and grassy swamps. 

Highly disturbed habitasite could provide mar

Golden eagle (Aquila chrysaetos) 

S1N No effect. Open areas in prairies, alpine and 

arctic tundra, woodlands, and hilly or mountainous regions. 

Suitable habitat does Project site. 

Swallow-tailed kite (Elanoides forficatus) 

S2B No effect. Tall trees for nesting and open areas 

for foraging. 

Suitable habitat does Project site. 

Yellow rail (Coturnicops noveboracensis) 

S2N Not likely to 

adversely affect. 

Emergent wetlands, grass or sedge marshes, and wet freshwater meadows. 

Highly disturbed habitasite could provide mar

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TABLE 4.6.2-1 (continued) 

State Listed Species Eliminated From Further Consideration for the Casotte Landing LNG Projec

Species State Status Project Effect Habitat Potential 

Amphibians Dark gopher frog (Rana sevosa)

S1 No effect. Sandy soil that was previously forested. 

Breeds in forested wetlands. Utilizes gopher tortoise burrows. 

Suitable habitat does Project site. 

One-toed amphiuma (Amphiuma pholeter) 

S1 No effect. Deep, organic, liquid mud in alluvial 

swamps of low-gradient 2nd and 3rd

order streams, spring runs, and occasionally floodplain swampy terrace streams. 

Suitable freshwater haproposed Project site. 

River frog (Rana heckscheri) 

S1 No effect. Swamps along streams and margins of 

shallow ponds. Eggs and larvae develop in permanent swamp waters. 

Suitable freshwater haproposed Project site. 

Reptiles Rainbow snake (Farancia erytrogramma) 

S2 Not likely to 

adversely affect. 

In or near rivers, streams, swamps, springs, open marshes, and sandy fields near water. 

Highly disturbed habitasite could provide mar

_______________ Notes: 

S1 — Critically imperiled in Mississippi because of extreme rarity (5 or fewer occurrences or very few remaining individuals or acres) or because of 

vulnerable to extirpation. 

S2 — Imperiled in Mississippi because of rarity (6 to 20 occurrences or few remaining individuals or acres) or because of some factor(s) making it v

S3 — Rare or uncommon in Mississippi (on the order of 21 to 100 occurrences). SZ — Zero occurrences in the state. Not of practical conservation concern in the state, because there are no definable occurrences, although the 

regularly in the state. 

Breeding Status: (Applicable to migratory species, mainly birds, but also includes sea turtles, some fish, and some insects). 

B — Breeding Status N — Non-breeding Status 

Sources: Mississippi Museum of Natural Science – Natural Heritage Program (including letter dated March 31, 2005) 

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TABLE 4.6.2-2 

State Listed Species Potentially Affected in the Casotte Landing LNG Project Area 

Species State Status Project Effect Habitat Potential 

Reptiles Gulf salt marsh snake (Nerodia clarkii clarkii) 

S2 Not likely to 

adversely affect. 

Estuarine; coastal salt marshes containing cordgrass (Spartina sp.), rush (Juncus sp.), and pickle weed (Salicornia sp.). 

Marginal habitat occursite, but is considered was not observed duri

Mississippi diamond terrapin (Malaclemys terrapin pileata) 

S2 Not likely to 

adversely affect. 

Coastal marshes, tidal flats, coves, estuaries, and lagoons behind barrier beaches; brackish and salt water. Nests in sandy marsh margins, offshore islands, and dunes. 

Marginal habitat occursite, but is considered nesting habitat is not rupland marsh habitats development. The spduring field surveys. 

Birds American white pelican (Pelecanus erythrorhynchos) 

S2N Not likely to 

adversely affect. 

Rivers, lakes, reservoirs, estuaries, bays, marshes. May utilize dredge spoil or natural islands. 

Marginal habitat occursite, but is considered was not observed durirepresents a highly moavoid disturbance. 

Gull-billed tern (Sterna nilotica) 

S2?B, S4?N 

Not likely to adversely affect. 

Coastlines, salt marshes, estuaries, lagoons, plowed fields, and occasionally along rivers and freshwater marshes. 

Marginal habitat occursite, but is considered was not observed durirepresents a highly moavoid disturbance. 

Least tern (Sterna antillarum) 

S3B, SZN 

Not likely to adversely affect. 

Shallow and deepwater marine and lacustrine habitats and beach dunes 

Marginal habitat occursite, but is considered was not observed durirepresents a highly moavoid disturbance. 

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TABLE 4.6.2-2 (continued) 

State Listed Species Potentially Affected in the Casotte Landing LNG Project Area 

Species State Status Project Effect Habitat Potential 

Birds Royal tern (Sterna maxima) 

S1B, S4N 

Not likely to adversely affect. 

Seacoasts, lagoons, estuaries, mudflats, sandspits, salt pond dikes and rarely on lakes. 

Marginal habitat occursite, but is considered was not observed durirepresents a highly moavoid disturbance. 

_______________ Notes: 

S1 — Critically imperiled in Mississippi because of extreme rarity (5 or fewer occurrences or very few remaining individuals or acres) or because of 

vulnerable to extirpation. 

S2 — Imperiled in Mississippi because of rarity (6 to 20 occurrences or few remaining individuals or acres) or because of some factor(s) making it v

S3 — Rare or uncommon in Mississippi (on the order of 21 to 100 occurrences). S4 — Widespread, abundant, and apparently secure in the state, but with cause for long-term concern (more than 101 occurrences). SZ — Zero occurrences in the state. Not of practical conservation concern in the state, because there are no definable occurrences, although the 

regularly in the state. 

Qualifiers: 

? — Inexact 

Breeding Status: (Applicable to migratory species, mainly birds, but also includes sea turtles, some fish, and some insects). 

B — Breeding Status N — Non-breeding Status 

Sources: Mississippi Museum of Natural Science – Natural Heritage Program (including letter dated March 31, 2005) 

NOAA Fisheries (including letter dated June 8, 2005) 

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4.6.2.2 Marine Mammals 

The Marine Mammal Protection Act regulates activities that may adversely affect marine 

mammals in waters of the United States. Federally protected whales and the Florida manatee are 

discussed above. Other marine mammals including pantropical spotted, bottlenose, and spinner dolphins 

and several other species of whales and dolphins may occur in the Gulf of Mexico (MMS 2006). Due to 

the mobility of many dolphin species, the planned use of wildlife observers during marine construction 

activities, Bayou Casotte Energy’s implementation of NOAA Fisheries’ Vessel Strike Avoidance and 

Injured/Dead Protected Species Reporting policy, and the other measures discussed above, we conclude 

that the proposed Project would not be likely to adversely affect marine mammals. 

4.6.2.3 Migratory Birds 

The Migratory Bird Treaty Act regulates taking of or impacts to migratory birds, including their 

nests. Migratory birds would be expected to occur at least as transients at the proposed Project site. 

However, given the fragmented and generally low quality nature of the habitats found at the proposed 

terminal site and along the pipeline interconnects, as well as the availability of more suitable habitats 

nearby, the potential for occurrence of migratory birds and/or their nests would be greatly reduced. 

However, in order to avoid adverse impacts to resident and migratory bird species, the FWS has 

recommended that clearing of terrestrial habitats be conducted outside the peak nesting season (April 1 

through June 30). As currently proposed, Bayou Casotte Energy would complete clearing and site 

preparation during the first quarter of 2007, which would be consistent with the FWS guidance. In order 

to adequately protect nesting birds, we recommend that: 

• Bayou Casotte Energy should consult with the FWS regarding appropriate measures 

that should be implemented to avoid or minimize impacts to migratory bird species if 

construction activities were to occur during peak nesting season (April 1 through 

June 30). In addition, Bayou Casotte Energy should file the results of that consultation 

with the Secretary and receive written approval from the Director of OEP prior to 

implementing any associated mitigation measures. 

Given the nature of the habitats available and our recommendation above, we conclude that the 

proposed Project would not be likely to adversely affect migratory birds or their nesting habitat. 

4.6.3 Conclusions and Recommendations 

The proposed Project site and adjacent Bayou Casotte are already highly disturbed, industrialized, 

and regularly dredged. Nesting habitats for the bald eagle and brown pelican are lacking in the area that 

would be affected by the proposed Project. Additionally, Bayou Casotte Energy has agreed to adopt and 

comply with NOAA Fisheries’ Vessel Strike Avoidance and Injured/Dead Protected Species Reporting 

policy and its Pile-Driving Harm Avoidance and Listed Species / Critical Habitat and Vessel Impacts 

guidelines. Therefore, we expect that construction and operation of the proposed Project would be not be 

likely to adversely affect federally or state threatened and endangered species, marine mammals, or 

migratory birds. However, while beneficial to general wildlife, fisheries, and vegetation in the area, these 

measures would also benefit listed species with the potential to occur in the vicinity of the project. In 

conclusion, we recommend that:

• Bayou Casotte Energy not begin construction activities at the LNG terminal and along 

the pipeline route until: 

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a. the FERC completes any necessary consultations with the FWS and NOAA 

Fisheries; and 

b. Bayou Casotte Energy receives written notification from the Director of OEP 

that construction and/or implementation of conservation measures may begin. 

• If construction has not begun within 1 year from the date of issuance of the FERC 

approval of the project, Bayou Casotte Energy should consult with the appropriate 

offices of the FWS and NOAA Fisheries to update the species list and to verify that 

previous consultations and determinations of effect are still current. Documentation of 

these consultations, and the need for additional surveys and survey reports (if required), 

and FWS or NOAA Fisheries comments on the surveys and survey reports and their 

conclusions, should be filed with the Secretary and the COTP before beginning 

construction. 

4.7 LAND USE, RECREATION AND VISUAL RESOURCES 

The proposed Project, located entirely within Jackson County, Mississippi, would affect a total of 

313.0 acres of land during construction (see Table 4.7-1). The proposed terminal site is a 259.4-acre 

parcel that consists of previously disturbed sediments and existing industrial areas located south of 

Chevron’s Pascagoula Refinery. The proposed pipeline interconnect system would be used to transport 

gas to existing infrastructure. It would include a 36-inch-diameter interconnect spur extending about 

1.5 miles north along Ranson Road and then east to the existing 36-inch-diameter Gulfstream pipeline. 

Two 16-inch-diameter and two 12-inch-diameter laterals would branch off the 36-inch-diameter spur and 

interconnect with other existing pipelines. The spur and laterals would require an additional 17.4 acres of 

construction right-of-way. Bayou Casotte Energy has indicated that no additional acreage would be 

required for extra workspace and staging areas outside the terminal site. An additional 36.2 acres of 

right-of-way would be associated with construction of nonjurisdictional facilities. 

Due to the collocation of the spurs and laterals, only 7.9 acres of new right-of-way would be 

required for operation of the jurisdictional facilities. The nonjurisdictional NGL pipeline and meter 

station would require 8.6 acres of new right-of-way during operation (see Table 4.7-2). 

Potential land use impacts include alterations to the current land use, the imposition of easements, 

and impacts on existing residences or planned developments. Recreation could be impacted if 

construction or operation of the proposed Project limited access to recreational sites or reduced enjoyment 

of those sites once access was gained. Recreational impacts could also occur along the waterway from 

the territorial seas to the facility’s berthing area due to potential security zones imposed around the LNG 

marine traffic, if the Coast Guard issues a LOR finding the waterway to be suitable for LNG vessel traffic 

with conditions. Impacts to visual resources are dependent upon the existing viewscape, the alteration to 

that viewscape, the sensitivity of viewers, and the number of potential viewers. 

4.7.1 Land Use 

4.7.1.1 Terminal Site 

The proposed LNG terminal site is a 259.4-acre parcel of land located east of Pascagoula, 

Mississippi. The majority of this parcel consists of previously disturbed and developed industrial areas, 

which include 119.3 acres of wetland (see Table 4.7-1). The Chevron Pascagoula Refinery is adjacent to 

the proposed terminal site to the north, Bayou Casotte is adjacent to the west, and wetlands are adjacent to 

the south and east. The nearest non-industrial development is approximately one-mile northwest (Google 

Maps 2005). 

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TABLE 4.7-1 

Acreage Used During Construction 

 Wetlands 

Upland 

Forest 

Open 

Space 

Existing Rightof-Way Open Water Co

Jurisdictional Facilities Terminal Site 119.3 0.0 0.0 0.0 25.5 Interconnect Spur and Laterals 12.5a 0.0 0.0 2.1 0.0 Meter Station (Interconnect Laterals) 1.5a 0.0 0.0 0.0 0.0 Meter Station (Interconnect Spur) 1.3a 0.0 0.0 0.0 0.0 Total for Jurisdictional Facilities 134.6 0.0 0.0 2.1 25.5 Nonjurisdictional Facilities Circulation Water System to Cooling Tower 1 and 2 0.0 0.0 0.0 0.0 0.0 NGL Interconnect Pipeline 11.1a 0.0 0.0 0.0 0.0 Meter Station (NGL Interconnect Pipeline) 1.2a 0.0 0.0 0.0 0.0 Total for Nonjurisdictional Facilities 12.3 0.0 0.0 0.0 0.0 Total 146.9 0.0 0.0 2.1 25.5 _______________ a Acreage described as wetland may also be in existing Right-of-Way. b This total does not include acreage associated with the Mississippi Power Company transmission line, classified as nonjurisdictional facility. 

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TABLE 4.7-2 

Acreage Converted from its Current Designation During Operation 

 Wetlands Upland Forest Open Space Existing Transportation, Utility, or Communication Right-of-Way Open Water 

Jurisdictional Facilities Terminal Site 119.3 0.0 0.0 0.0 25.5 Interconnect Spur and Laterals 6.1a 0.0 0.0 0.0 0.0 Meter Station (Interconnect Laterals) 0.9a 0.0 0.0 0.0 0.0 Meter Station (Interconnect Spur) 0.9a 0.0 0.0 0.0 0.0 Total for Jurisdictional Facilities 127.2 0.0 0.0 0.0 25.5 Nonjurisdictional Facilities Circulation Water System to Cooling Tower 1 and 2 0.0 0.0 0.0 0.0 0.0 NGL Interconnect Pipeline 0.2a 0.0 0.0 0.0 0.0 Meter Station (NGL Interconnect Pipeline) 0.7a 0.0 0.0 0.0 0.0 Total for Nonjurisdictional Facilities 0.9 0.0 0.0 0.0 0.0 Total 128.1 0.0 0.0 0.0 25.5 _______________ a Acreage described as wetland may also be in existing Right-of-Way. b This total does not include acreage associated with the Mississippi Power Company transmission line, classified as nonjurisdictional facility. 

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If the proposed Project were constructed, 49 acres within the proposed terminal site would be 

permanently converted to open water. The site would include docking equipment, regasification 

equipment, LNG storage tanks, and associated buildings. During construction, the site would also include 

a laydown area, a workshop and pre-assembly area, a MPC substation yard, and a concrete batch plant. 

Following construction, those areas not utilized for an industrial application would be allowed to 

revert to pre-construction conditions. 

Given the existing setting, the relatively small acreage, the existing cover type, and the federal 

requirement to mitigate wetland impacts, construction and operation of the proposed LNG terminal would 

represent a negligible, long-term land use conversion. 

4.7.1.2 Pipeline Interconnect System 

The 36-inch-diameter Gulfstream Pipeline interconnect spur and four laterals would connect the 

proposed LNG terminal to existing natural gas infrastructure. The 36-inch-diameter spur would extend 

1.5 miles beyond the terminal site to a point where it would connect to the existing Gulfstream Pipeline. 

The four interconnect laterals would branch off at MP 0.5. The total length of the nonjurisdictional NGL 

pipeline would be about 4.3 miles. As proposed, construction right-of-way along the 36-inch-diameter 

interconnect spur and collocated 12-inch-diameter NGL pipeline interconnect would be 110 feet wide. 

Where only one pipeline would be within the right-of-way, width would be reduced to 85 feet. 

These pipeline and lateral interconnects would require 14.6 acres of right-of-way during 

construction (see Table 4.7-1) in addition to the acreage within the proposed terminal site. 

Approximately 86 percent of those 14.6 acres are currently designated as wetland and are owned by 

utilities or other industrial interests. Assuming a 50-foot operational right-of-way would be associated 

with the 1 mile of 36-inch-diameter Gulfstream interconnect, were it not collocated with the 

nonjurisdictional 12-inch-diameter NGL pipeline, about 6.1 acres of new permanent right-of-way would 

be required for operation (see Table 4.7-2). 

During construction, acreage within the pipeline interconnect right-of-way would be temporarily 

converted to open space. Following construction, hydrological gradients and flow patterns would be 

restored. All disturbed acreage outside the permanent right-of-way would be allowed to revert to 

pre-construction conditions. Acreage within the permanent right-of-way would be maintained free of 

woody vegetation. The proposed pipeline interconnects would be constructed and maintained in 

accordance with measures contained in Bayou Casotte Energy’s Plans and Procedures, as modified in this 

EIS. 

Given the existing setting, the relatively small acreage, and the federal requirement to mitigate 

wetland impacts, construction and operation of the proposed pipeline interconnect system would represent 

a negligible, long-term impact.

4.7.1.3 Extra Work Space and Staging Areas 

Bayou Casotte Energy has indicated that all of the acreage required for extra workspaces and 

staging would be located within the proposed LNG terminal site. 

4.7.1.4 Above ground Facilities Outside the Proposed Terminal Site 

Two meter stations would be associated with the interconnect spur and laterals, with an additional 

meter station for the nonjurisdictional NGL interconnect pipeline (see Table 4.7-1 and Table 4.7-2). The 

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jurisdictional meter stations would be located at the tie-in locations to the existing pipelines. The first tiein location is associated with four existing pipelines: the 16-inch-diameter Destin pipeline, a 

16-inch-diameter and 12-inch-diameter Chandeluer, and the 12-inch-diameter Gulf South, while the 

second ties into the Gulfstream pipeline. 

The land required for the meter stations is currently classified as wetland but it is also in an 

existing right-of-way. The proposed Project would require these areas to be filled and a hurricane levee 

would be constructed around the perimeter of each meter station. As such, the above ground facilities 

located outside the proposed terminal site would represent the conversion of 1.8 acres of land currently 

classified as wetlands and maintained as industrial right-of-way to commercial industrial right-of-way. 

This would be a permanent (for the life of the Project) impact to the land classification. 

4.7.1.5 Access Roads 

Bayou Casotte Energy anticipates that existing access roads, in conjunction with proposed rightsof-way, would be sufficient to meet both construction and operation needs of the proposed Casotte 

Landing Project. Moreover, no improvements or modifications to existing roads, or construction of new 

roads outside the terminal site are expected. 

4.7.1.6 Disposal of Spoils from Slip Creation 

The proposed Project would include the creation of a marine slip to be situated less than 

0.25 miles north of the mouth of Bayou Casotte. This slip, created by removing soil and sediments from 

the proposed terminal site, would serve to promote ease of navigation, alleviate congestion and delays 

within the channel, and simultaneously accommodate an LNG carrier and a crude tanker. 

Bayou Casotte Energy has indicated that about 22 percent of the dredged spoils would be used for 

both on and off-site construction needs such as fill, site leveling, and hurricane levee construction. The 

remaining 78 percent would be transported to placement locations. Preferred placement options, as 

outlined in Bayou Casotte Energy’s DMMP, are at the Pascagoula ODMDS or at approved and available 

Federal and state coastal or offshore Beneficial Use projects sites, or some combination thereof (see 

Appendix E). Final agency approval for disposal at the ODMDS has not been granted by the COE or 

EPA. 

4.7.1.7 Nonjurisdictional Facilities 

Nonjurisdictional facilities would include two relocated refinery ship berths, electric transmission 

lines, connections to a circulating water cooling system, and the 12-inch NGL interconnect pipeline. 

Acreage associated with the ship berths is included in discussions of the proposed LNG marine 

terminal. The electric transmission lines would be constructed by Mississippi Power. The exact timing 

for construction and route of the transmission lines has not been determined; therefore, land use impacts 

as a result of constructing and operating this system have not been addressed. 

The circulating water cooling system and the 12-inch-diameter NGL pipeline facilities would 

require 36.2 acres of right-of-way during construction and maintenance of about 8.6 acres of new 

permanent right-of-way during operation (see Tables 4.7-1 and 4.7-2). Construction disturbance would 

primarily be associated with commercial industrial land (66 percent), with wetlands comprising the 

remainder (34 percent). Following construction, hydrological gradients and flow patterns would be 

restored to all disturbed acreage. The area outside the permanent right-of-way would be allowed to revert 

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to pre-construction conditions. Acreage within the permanent right-of-way would be maintained free of 

woody vegetation. 

4.7.2 Existing Residences and Planned Developments 

The nearest residence is approximately one-mile northwest of any proposed Project component. 

The majority of land within one mile of the proposed Project components is open water, wetland, or land 

owned by industrial interests. Bayou Casotte Energy indicated that construction notices would be 

distributed to landowners within one mile and minimization techniques would be used to reduce any 

potential impacts such as dust and noise. As such, terminal construction would not significantly impact 

any existing residences. No residences or planned residential developments are located along the 

centerline of the LNG ship transit route. 

Two planned industrial developments have also been identified in the immediate area. One 

known planned development is an expansion by Chevron Pascagoula Refinery to increase processing 

capacity by 15,000 barrels per day by upgrading its Fluid Catalytic Cracking Unit (FCCU). Upgrades to 

the FCCU would also require upgrading and replacing other process equipment at the refinery; however, 

all expansion activities are currently planned to take place within the existing refinery property on land 

already developed industrially. Since Chevron is a participant in the proposed Project, no conflicts are 

perceived with the proposed Casotte Landing Project. 

Gulf LNG Energy has also filed an application with the FERC to construct, own, and operate an 

LNG import terminal and natural gas pipeline. Gulf LNG’s proposed terminal is located south of the 

proposed Casotte Landing LNG Terminal on Bayou Casotte. The FERC is currently preparing a separate 

EIS for the Gulf LNG Energy project. 

4.7.3 Recreation and Special Interest Areas 

All of the land that would be used for the proposed Project is privately owned. The FERC has not 

identified any designated natural, recreational, or scenic areas within 1.0 mile of the proposed LNG 

terminal site or pipeline interconnects. It is also noted that portions of Bayou Casotte are in the Bayou 

Casotte-Bangs Lake Special Management Area (SMA) which were established as part of the SMA 

Planned for the Port of Pascagoula. The nearest designated special interest area, located about 1.0 mile to 

the east and southeast, is The Nature Conservancy’s Grand Bay National Estuary Research Reserve 

(NERR). The oldest standing structure in the Mississippi Valley, the Old Spanish Fort, and Shepards 

National Park are within 6 miles of the proposed Project (American Forts East 2005). During transit to 

the LNG terminal, the LNG marine traffic would pass between Petit Bois and Horn Islands, which are 

included as part of the Gulf Islands National Seashore. 

4.7.3.1 Gulf Islands National Seashore 

In 1971 the National Seashore was established for preservation of coastal islands, historic forts 

and other historic structures, nature trails, and adjacent open waters (NPS 2005). In 1978, congress set 

aside Horn and Petit Bois Islands as wilderness areas within Gulf Islands National Seashore. These areas 

are several miles south of the proposed facilities and would not be affected by the construction or 

operation of the proposed LNG terminal. As discussed previously, LNG marine traffic would transit the 

confined areas of Horn Island Pass en route to the LNG terminal, Section 4.1.3.6 contains a discussion 

of the potential for shoreline erosion on Horn Island due to LNG marine traffic. Additional information 

on the environmental impacts resulting from the transit of the LNG ships is provided in Section 4.13.5.3. 

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4.7.3.2 Grand Bay National Reserve, Mississippi 

The Grand Bay National Reserve is an 18,400-acre reserve that was designated in 1999 due to its 

ecological productivity and limited development (Project Summary 2005 and American Forts East 2005). 

The reserve includes saltwater marshes, maritime pine forest, pine savanna and pitcher plant bogs, as well 

as supporting oyster reefs and seagrass habitat (National Estuary Research Reserve System 2005). 

Recently an archaeological survey found 16 American Indian earth and shell middens within the reserve 

(Mississippi DMR 2005). Principal threats to the Grand Bay National Reserve are habitat loss, fire 

suppression, exotic species, alteration of hydrology, and water quality degradation (Project 

Summary 2005). 

4.7.3.3 Port of Pascagoula 

In November of 1985 the Mississippi Commission on Wildlife Conservation gave approval for 

the Port of Pascagoula SMA Plan to be part of the Coastal Program. The primary purpose of which is to 

balance industrial development and the coastal environment. 

The SMA task force divided the Port of Pascagoula into two separate planning areas: the Bayou 

Casotte-Bangs Lake Planning Area and the Pascagoula River Harbor-Middle River Planning Area. The 

proposed LNG terminal would be located in the Bayou Casotte-Bangs Lake Planning Area. This area is 

comprised primarily of undeveloped tidal marsh and open water. 

Given the proposed Project site is an existing industrial area, and the pipeline interconnects fall 

into existing rights-of-way, no impacts are expected to these, or any other special interest area, during 

construction or operation of the proposed Project. 

4.7.3.4 Recreational Boating and Fishing 

Recreational fishing in the area is limited to boat-based activity with the nearest public access 

boat ramp located at Lander Avenue about 1.9 miles away. This relatively small site generally provides 

access to fewer than 20 boats per day. 

Construction and operation of the proposed Project could displace recreational boating and 

fishing on Bayou Casotte during construction and operation, if the LOR is issued with conditions by 

Coast Guard. Boaters and fishermen could need to avoid construction vessels as they delivered material 

to the site. While on their inbound and outbound routes or docked, LNG marine traffic could have a 

security zone enforced around them. Other vessels, including recreational boats, could be prohibited 

within the security zone during the arrival, departure, or mooring of LNG carriers. These effects could be 

temporary while the LNG carrier is in transit or moored at the LNG carrier unloading dock. The 

maximum delay expected due to the transit of an LNG carrier could be 1.5 hours. The extent of the 

security zone around the LNG carrier while it is unloading could be established by the Coast Guard but is 

not expected to interfere with traffic along the adjacent Bayou Casotte Channel. 

Furthermore area bathymetry suggests that recreational and fishing vessels could be able to 

navigate Bayou Casotte to the Gulf of Mexico through outside-channel portions of the waterway. As 

such, potential displacement could be limited to the relatively few recreational operating boats in direct 

proximity to either the shipping lanes or the proposed terminal location. These displacements could 

represent a minor, periodic inconvenience to fishermen and recreational boaters that could persist for the 

life of Project, if the LOR is issued with conditions by the Coast Guard. 

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4.7.4 Visual Resources 

The degree of visual impact associated with a project is a function of the existing viewscape, 

alterations to that viewscape, the number of potential viewers, and their sensitivity. 

All Project components would be located in an industrial viewscape situated in relatively flat 

topography. The dominant anthropogenic component is the Chevron Pascagoula Refinery, which 

contains large storage tanks, and industrial facilities up to 100 feet tall. To the west is Bayou Casotte a 

dredged inlet used for both recreational and industrial applications. 

During construction, the terminal site would include all of the equipment and activity typically 

associated with a large construction project. When complete, storage tanks estimated at 168 feet tall 

would dominate the proposed terminal site. Safety lighting would be required on the mooring dolphins, 

uploading platform, and the highest points of the storage tanks. 

This viewscape would be observed by those who work in and around the complex, boaters on 

Bayou Casotte, and residents who would be located approximately 1 mile from proposed Project 

components. These viewers would generally be familiar with the views associated with energy 

infrastructure and would have grown accustomed to views of similar infrastructure at this site. 

The level of marine traffic in and approaching Bayou Casotte, currently about 2,800 arrivals per 

year, would increase about six percent in association with increased LNG carrier traffic. These LNG 

carriers are generally less than 1,000 feet in length and draft up to 38 feet. Given the unique appearance 

of their moss tanks, LNG carriers are quite distinctive and they would be visible form several locations as 

they approached the proposed site. However, their appearance would be similar in size and duration to 

the existing Bayou Casotte traffic. 

During construction, activity would be viewed by some visual receptors, as minor viewscape 

degradation while others would likely derive some enjoyment from watching the activity. Once complete 

the proposed LNG terminal site would represent a long-term, minor degradation of an already 

industrialized viewscape. 

4.7.5 Coastal Zone Management (CZM) consistency 

The CZM Act provides states whose CZM programs have met federal approval the power to 

review any project proposed within that state’s coastal zone. Projects that require federal licenses or 

permits must draft a “consistency certification” to assure the proposed project meets the state’s CZM 

program standards. CZM consistency for the Coast Guard’s establishment of a moving safety zone and a 

safety zone around the LNG facility must also be determined. 

Portions of the proposed Project fall within the coastal zone managed by the MDMR and the 

Pascagoula Special Management Area (SMA). MDMR is currently conducting a consistency review. 

Therefore, we recommend that: 

• Bayou Casotte Energy file documentation of concurrence from the Mississippi 

Department of Marine Resources that the Project is consistent with Mississippi’s CMP 

with the secretary prior to construction and transit route usage. 

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4.8 SOCIOECONOMICS 

The proposed Project includes construction of a marine slip and berth for offloading LNG, 

relocation of two existing refinery berths, and construction of facilities to receive and regasify LNG for 

transport to components of the existing natural gas transportation infrastructure. The 259.4-acre terminal 

site is located south of the existing Chevron Pascagoula Refinery in Jackson County, Mississippi. 

Several potential socioeconomic effects could be associated with construction of the proposed 

Project. These include altering local demographics, increased employment opportunity, increased 

demand for housing, and altered property values. Other potential construction effects would include 

increased government revenue associated with sales and payroll taxes, increased demand for the provision 

of public services, changes to local commerce, and increased utilization of local transportation 

infrastructure. 

Economic activity associated with the operation of the proposed Project would include 

employment opportunities, ongoing local expenditures by the operating company, and an increased tax 

base. 

The FERC notes that this EIS is being prepared while the communities surrounding the proposed 

Project area are still recovering from the aftermath of Hurricane Katrina. However, the following section 

has been updated, as appropriate, to provide additional information regarding the socioeconomic impacts 

on the Project area associated with Hurricane Katrina. 

4.8.1 Population 

Table 4.8.1-1 summarizes selected socioeconomic statistics for Mississippi, Jackson County, and 

Pascagoula prior to Hurricane Katrina. Populations in all areas were increasing though growth in 

Pascagoula had been slower than state and county averages. All areas were predominantly white nonHispanic with African Americans making up the majority minority. These residents were living at 

population densities that are typical of rural areas. 

TABLE 4.8.1-1 

Selected Socioeconomic Statistics 

Location Population 

Persons 

per 

Square 

Mile 

White, 

non 

Hispanic 

(%) 

African 

American 

(%) 

Hispanic 

(%) 

Asian 

(%) 

Native 

American 

(%) 

Annual 

Growth 

Rate 

(%) 

Mississippi 2,881,281 60.6 60.7 36.3 1.4 0.7 0.4 1.3 

Jackson County 133,928 180.8 74.2 20.9 2.1 1.6 0.3 1.9 

City of 

Pascagoula 26,200 1,726.4 67.2 29.0 3.9 1 0.2 0.4 

_________ 

Source U.S. Census Bureau, 2005 

Construction of the proposed Casotte Landing Project would occur between 2007 and 2010. 

During the two years of peak construction, 400 to 600 workers would be involved in construction activity. 

When available, suitably skilled, local workers would be used for construction. During past projects of 

this nature, non-local workers specializing in the construction of LNG terminals typically comprised 

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about 30 percent of the labor force (FERC 2005). For this Project, additional, non-local workers may be 

required depending upon the impacts to those displaced by Hurricane Katrina. 

Construction of the proposed Project would result in a minor, short-term population increase in 

the local area. If non-local workers represent 30 percent of the work force and 0.8 persons accompanied 

each worker, total in-migration would be 324. This would represent a minor influx of persons into 

Jackson County. 

During operation, Bayou Casotte Energy estimates that approximately 50 full-time workers 

would be employed. This would represent a negligible, long-term effect on population demographics. 

4.8.2 Economy and Employment 

In 2000, Mississippi’s largest employment sector was education, health, and social services; 

manufacturing led Jackson County and Pascagoula. In addition, Pascagoula and Jackson County had 

lower unemployment rates and higher per capita incomes that the rest of Mississippi (see Table 4.8.2-1). 

TABLE 4.8.2-1 

Employment Statistics 

Location 

Per Capita 

Income in 

1999 

Civilian Labor 

Force in 2000 

Percent 

Unemployed 

Top Employment 

Industry 

Mississippi $15,853.00 1,267,092 6.9 Education, health and 

social services 

Jackson County $17,768.00 60,617 6.1 Manufacturing 

City of Pascagoula $16,891.00 11,230 5.3 Manufacturing 

__________ 

Source U.S. Census Bureau, 2005 

Following Hurricane Katrina, economic activity along Mississippi’s Gulf coast changed 

significantly. Current statistics are difficult to obtain but a much larger portion of economic activity 

currently centers on recovery and construction than was the case prior to the storm. 

During the two years of peak construction, as many as 420 construction positions may be filled 

by local workers. Additional jobs could also be created as a result of secondary activity associated with 

construction of the proposed Project. This is because Bayou Casotte Energy has indicated it will take 

proactive measures to ensure that local suppliers and service providers have the opportunity to submit 

proposals. In addition, purchases made by non-local workers on food, clothing, lodging, gasoline, and 

entertainment will have a temporary, stimulatory effect on the local economy. These positions could 

represent a moderate increase in employment opportunities for an economy that is recovering from a 

major natural disaster. 

The 50 positions created during operations would represent a minor, long-term increase in local 

employment opportunities. 

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4.8.3 Housing 

The U.S census bureau (2005a) reported that the number of rental units in Jackson County for the 

year 2000 was 1,367, with an additional 613 units available for seasonal, recreational, or occupational 

use. An additional 808 rooms and R/V sites are available at 10 area establishments based on information 

from the American Automobile Association. Following Hurricane Katrina, it is difficult to assess the 

stock of existing and/or available housing. 

If non-local workers represent 30 percent of the workforce and each non-local worker required 

his or her own housing, 180 units could be required during the two years of peak construction activity. 

Given the nearly 2,800 potentially available units in Jackson County prior to the storm this would 

represent a minor, short-term reduction of available housing units. During operations, impacts to housing 

would be negligible. 

Given the recent events associated with Hurricane Katrina, the potential impact to local housing 

stock as it will appear in 2007 is difficult to determine. To date, FEMA has created temporary housing 

called Emergency Group Sites (EGS) that accommodate between 10 and 200 manufactured housing units. 

There are currently three completed EGS with more under review or construction. In addition, the city of 

Pascagoula reports hotels in the Project area are reopening. Given the 2007 to 2010 construction time 

period, it seems likely that housing requirements associated with construction workers would result in a 

moderate, short-term tightening of the available housing market. During operations, impacts to housing 

would be negligible. 

4.8.4 Property Values 

The FERC has received comments questioning whether the construction of an LNG terminal 

diminishes property values. The FERC notes that the impact a project may have on the value of any land 

parcel depends on many factors. These include the size of the parcel, the parcel’s current value and land 

use, and the value of other nearby properties. However, subjective valuation is generally not considered 

in appraisals. This is not to say that the proposed Project could not affect resale values. Potential 

purchasers may make a decision based on intended future use and, if the presence of the proposed Project 

would make that use infeasible, it is possible that that potential purchaser may not acquire the parcel. 

However, each potential purchaser has differing criteria and means. The FERC further notes that any 

potential effects on property values would be mitigated by the co-location of the proposed Project near an 

existing industrial facility. 

The FERC notes that, due to the location of the proposed terminal and collocation of pipeline 

right-of-way within existing right-of-way, the proposed Project would not require the negotiation of 

easements with individual parcel owners nor would there be any potential use of eminent domain. 

Therefore, property value changes associated with easement imposition are not at issue. 

The FERC has previously consulted with insurance professionals to determine if construction of 

an LNG terminal near an existing industrial facility would likely increase homeowners insurance rates 

(FERC 2004). The FERC has determined that homeowners' insurance rates are not likely to increase as 

the result of LNG terminal siting near existing industrial sites. 

4.8.5 Government Revenue 

During construction a portion of the $100 to $150 million dollar construction payroll would be 

spent locally for the purchasing of housing, food, gasoline, and entertainment. The exact amount would 

be dependent upon the behavior of individual workers and the duration of their stay. In addition, Bayou 

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Casotte Energy has indicated that local suppliers have the opportunity to submit proposals for Project 

related work. To the extent that these local providers bid successfully, local expenditures during 

construction would increase. The majority of these construction-related expenditures would be subject to 

Mississippi’s state sales tax of seven percent. Additional expenditures may be subject to Pascagoula’s 

hotel and room tax. This increase in sales tax would represent a minor, short-term increase in government 

revenues. 

During operation, taxable payroll expenditures would be approximately $3 million annually. In 

addition, the facility would be subject to property taxes. Associated tax revenues (Table 4.8.5-1) would 

represent a moderate, but long term increase in tax revenue. 

TABLE 4.8.5-1 

Estimated Local, County and State Taxes 

Tax Category Estimated Annual Payment (in 

thousands) 

Property 

County $6,477 

School $5,481 

Mississippi State 

Income $1,620 

Sales & Use $28 

While the presence of an industrial facility could, under some circumstances, reduce the assessed 

values of some parcels and hence taxes levied against them, the net effect on tax revenues would likely be 

positive, moderate, and long-term. 

4.8.6 Public Services 

Prior to Hurricane Katrina there were 491 fire, police, and medical full time equivalent positions 

in Jackson County (U.S. Census Bureau 2005b), a level typical of a semi-rural community. Table 4.8.6-1 

describes the local fire, police, and ambulance services prior to Hurricane Katrina. Most of these services 

are within approximately 5miles of the proposed Project area. Singing River Hospital, located in 

Pascagoula, has 415 licensed beds and a 24-hour emergency center. 

TABLE 4.8.6-1 

Local Fire, Police, and Ambulance 

Service Provider Employees 

Jackson County Ambulance Service 50 Medics 

Escatawpa Fire Dept. 4 Full Time Fire Fighters, 30 volunteer 

Moss Point Fire Dept. 39 Fire Fighters at 4 stations 

Pascagoula Police Dept. 57 Officers 

Pascagoula Fire Dept. 58 Fire Fighters at 3 stations 

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The Pascagoula Fire Department currently has the equipment and personnel necessary to handle a 

large, industrial-related emergency at the proposed LNG terminal. However, additional training 

specifically for LNG firefighting would be coordinated with Bayou Casotte. The fire department would 

also respond to any medical, hazardous materials, safety incidents, and other non-fire emergencies at the 

proposed LNG terminal. 

Although incidents are not anticipated, Bayou Casotte Energy has taken the precautions of 

preparing a SPCC Plan (see Appendix D) and an Emergency Response Plan (currently being prepared by 

Bayou Casotte Energy) in accordance with the Oil Pollution Act 1990 (OPA-90). An Emergency 

Response Plan would include procedures for coordinating with local, state, and federal emergency 

response authorities. Specific components of the plan consist of periodic informational meetings, drills, 

demonstrations, and training sessions associated with potential incidents involving facilities operated by 

Bayou Casotte Energy. 

Jackson County also had 3,293 full time equivalent education workers distributed throughout four 

public school districts and seven private or parochial schools. They served over 25,000 students (Jackson 

Chamber). The provision of these services was impacted by Hurricane Katrina. Individual service 

providers were displaced and facilities were damaged. By early 2006, area schools had re-opened and the 

provision of medical and policing services were normalizing. 

Project construction could temporarily increase the demand for permit issuance and law 

enforcement activities and impact the demand for local medical and education services. Given the peak 

workforce of 600, and a maximum expected in-migration of 324 individuals, the aforementioned sectors 

would experience a minor, short-term strain during construction and a negligible, long-term impact during 

operation. In addition, any increase in demand for public services could be partially or wholly offset by 

the proposed Project’s related increase in government revenue. 

4.8.7 Local Commerce 

Potentially significant effects on economic sectors not associated with energy production are 

limited to marine based transportation. These impacts, primarily resulting from the LNG vessel traffic 

along the waterway from the territorial seas to the berthing facility, are discussed in Section 4.9. 

4.8.8 Environmental Justice 

In December 1997 the Council on Environmental Quality called upon the Federal agencies to 

actively scrutinize the following issues with respect to environmental justice (CEQ 1997): 

• the racial and economic composition of affected communities; 

• health related issues that may amplify Project effects on minority or low-income individuals; 

and 

• public participation strategies, including community or tribal participation in the process. 

4.8.8.1 Racial and Economic Composition 

Tables 4.8.1-1 and 4.8.2-1 summarize the demographic composition and economic status of 

Jackson County residents. They are not indicative of a community that is disproportionately low income 

or minority. 

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4.8.8.2 Public Health 

The primary health issue related to the Project is the risk associated with cryogenic or thermal 

impacts from an accidental or intentional release during LNG vessel transit along the waterway, facility 

fires or pipeline failure. Section 4.12 addresses these risks and the measures that would be taken to 

minimize them. These risks would not be disproportionately borne by any minority or low-income group. 

4.8.8.3 Public and Community Participation 

Bayou Casotte has conducted two open houses: March 3, 2005 at the Pascagoula High School and 

August 4, 2005 at the Pascagoula Civic Center. In addition, the NEPA process is designed to solicit 

public input during preparation of the EIS and all public documents filed in association with this proposed 

Project can be accessed via the FERC’s website. On April 20, 2005, the FERC conducted a public 

scoping meeting in Pascagoula to provide an opportunity for the general public to learn more about the 

proposed Project and to participate in our analysis by commenting on issues to be included in the EIS. 

On December 7, 2005, the Coast Guard conducted a public meeting in Pascagoula to provide an 

opportunity for the general public to provide comments on waterway suitability and maritime safety and 

security aspects of the proposed LNG facilities. The FERC conducted a public comment meeting on 

June 22, 2006, in Pascagoula to provide an opportunity for the general public to comment on the draft 

EIS. 

4.8.8.4 Conclusions Regarding Environmental Justice 

The FERC believes the proposed Project is practical, economical, and designed to meet energy 

infrastructure needs while minimizing environmental, safety, and engineering concerns. The FERC has 

not identified any high adverse human health or environmental effects that would be borne 

disproportionately by any low income or minority group. 

4.9 TRANSPORTATION 

4.9.1 Marine Transportation 

More than 2,800 marine vessels, excluding tugs and tows, accessed Bayou Casotte via the Bayou 

Casotte Channel in 2002 (COE 2002). Traffic restricted to shipping channels included tankers calling on 

the Chevron Pascagoula Refinery, and vessels exporting both dry goods and timber. Fishing vessels and 

recreational boating traffic, while frequent, is not restricted to the main shipping channel. The Pascagoula 

Channel, from which the Bayou Casotte Channel branches, is also used by several hundred vessels per 

year to access the Port of Pascagoula via the Pascagoula River Harbor. 

Vessels that had been traveling along the Alabama or Mississippi coasts would likely arrive at the 

Pascagoula Channel via the Mississippi Intracoastal Waterway at a point north of Petit Bois and Horn 

Islands. Ships arriving from offshore, such as LNG carriers, could pass between Petit Bois and Horn 

Islands via the Horn Island Pass. All ships and large barges, regardless of their approach to Bayou 

Casotte, are required to be under the control of a Pascagoula Bar Pilot. Large vessels, such as LNG 

carriers, require two pilots. 

Findings of a traffic study (MNI 2005) identified vessels that were night restricted and extreme 

weather events as causing the majority of the existing marine traffic delays at Bayou Casotte. Conditions 

at the time of the study found average delays to be 0.8 hours for inbound traffic and 0.7 hours for 

outbound traffic. 

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Impacts during construction could be limited to the delivery of construction material; dredging of 

the Pascagoula and Bayou Casotte Channels is not anticipated. Deliveries could likely occur primarily 

via barge accessing the site from the Mississippi Intracoastal Waterway and then the Bayou Casotte 

Channel. 

During operation, approximately 170 LNG carriers per year, under the control of Pascagoula Bar 

Pilots, could access the proposed terminal via existing shipping channels from the territorial seas, if LOR 

issued by the Coast Guard finds the waterway suitable for LNG vessel traffic with conditions. The Coast 

Guard, with input from the Pascagoula AMSC, has completed a review of Bayou Casotte Energy’s WSA 

in accordance with the guidance in Coast Guard NVIC 05-05. The WSA review focused on the 

navigation safety and maritime security risks posed by LNG ship traffic, and the measures needed to 

responsibly manage these security risks. The WSA itself is designated Sensitive Security Information as 

defined in 49 CFR Part 1520. Because any unauthorized disclosure of these details could be employed to 

circumvent the proposed security measures, they are not releasable to the public. 

As a result of this review, the Coast Guard advised the FERC in its WSR letter dated 

April 1, 2006, that the Pascagoula Bar, Horn Island Pass, Lower Pascagoula, and Bayou Casotte Channels 

can accommodate the LNG vessel traffic associated with the project. The letter stated that these 

waterways can accommodate the proposed traffic and there is sufficient capability within the port 

community to responsibly manage the safety and security risks of this project. In a follow-up letter to 

the FERC dated September 5, 2006, the Coast Guard clarified that the April 1, 2006 letter gave a 

preliminary evaluation to meet the recommendations of NVIC 05-05. The evaluation is not final until the 

Coast Guard completes its NEPA Review. The September 5 letter also stated that any final determination 

of waterway suitability is contingent upon an evaluation of certain conditions including those identified in 

Section 2.0. With the completion of this Final EIS, the Coast Guard will complete its review and issue an 

LOR to address the suitability of the waterways for LNG transport. 

The FERC notes that, while Bayou Casotte Energy has designed a marine slip capable of 

servicing LNG carriers up to 200,000 m3

, which could require channel deepening, they are not planning 

to deepen the channel at this time. 

LNG marine traffic could enter the port area starting at the “HI” sea buoy and travel northeast to 

the Horn Island Pass. While transiting the Horn Island Pass, ships would turn from a northeasterly to a 

northern course. After transiting the Horn Island Pass, LNG marine traffic could cross the Mississippi 

Intracoastal Waterway and proceed to Bayou Casotte via the Bayou Casotte Channel. A similar course 

could be followed by exiting LNG marine traffic. The Pascagoula Pilot’s Association1

 restricts the 

passage of all LNG marine traffic to daylight hours due to LNG carrier sizes exceeding 700 feet in length 

and with beams greater than 125 feet. 

While moored, LNG carriers may have a security zone enforced around them prohibiting other 

vessels and recreational boats within the security zone, unless permission to enter the zone is obtained 

from the Captain of the Port. These effects could be temporary while the LNG carrier is moored at the 

unloading dock. The extent of the security zone around the LNG carrier while it is moored may be 

established by the Coast Guard but is not expected to interfere with traffic along the adjacent Bayou 

 

1 The Pascagoula Pilots are the controlling body in terms of scheduling, monitoring of weather conditions, 

establishing working conditions, and declaring channel closure days based on inclement weather. Pilots meet ships, 

day or night, at the sea buoy located at the southern end of the Horn Island Pass Channel. 

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Casotte Channel. An example of existing safety and security zones consist of 500 yards on either side of 

the vessel, and 1,000 yards from the bow and stern of the vessel. 

Bayou Casotte Energy conducted a marine traffic simulation. This simulation controlled for the 

one way restriction placed on large vessels, the one-half hour which must be maintained between 

incoming and exiting vessels, weather related travel restrictions, existing vessel traffic patterns, pilot and 

tug availability, and the potential growth of that traffic for reasons unrelated to the proposed Project. The 

results of Bayou Casotte Energy’s marine traffic simulations suggest that the proposed Project related 

arrivals may increase inbound marine traffic delays by 0.25 percent and outbound traffic delays by 

0.14 percent relative to current conditions. This could represent a moderate, long-term impact. 

The FERC notes that anticipated impacts of project related LNG carrier traffic are based on the 

assumption that the Coast Guard could establish a safety and security zone 2 miles ahead and 1 mile 

behind each LNG carrier. However, the one-half hour separation requirement for in and outbound traffic 

is more burdensome than the assumed Coast Guard safety and security zone. As such, results of the 

analysis are robust to minor changes in the assumed Coast Guard safety and security requirements. 

To summarize, Project construction could have only minor impacts on commercial and 

recreational boat traffic. These effects could be associated with the waterborne delivery and removal of 

construction materials. Other shipping activities would be moderately affected by the increase in traffic 

during operations; however, based on the relatively low volume of existing shipping activity in the 

berthing area to the territorial sea, the impact is not expected to be substantial. 

4.9.2 Land Transportation 

The area’s overland infrastructure includes U.S. Highway 90 that is an east to west highway 

located approximately 3.5 miles north of the proposed site. The proposed site is accessed from U.S. 

Highway 90 via Highway 611. Located several miles north of U.S. Highway 90 is Interstate Highway 10. 

Access to the site from Interstate 10 is via Highway 63 that turns into Highway 611. The proposed site 

can also be accessed via Bayou Casotte waters. 

The FERC notes that the current primary function of Highway 611 is to provide overland access 

to existing industrial facilities on Bayou Casotte. As such, traffic is light except during shift changes 

when more than 1,200 employees make their way to and from facilities in and around the proposed site. 

The FERC also notes that these roads are expected to be similar to pre-Hurricane Katrina conditions prior 

to the 2007 construction initiation. 

During the two years of peak construction, 400 to 600 workers would be involved in construction 

activity. Assuming 1.3 persons per vehicle implies an extra 308 to 462 commuter vehicles per day. This 

represents a three to five percent increase in roadway traffic on Highway 611. Bayou Casotte Energy has 

indicated that the majority of construction materials and oversized loads would be delivered via marine 

transport. As such, the impact of the proposed Project to local roadways is expected to be minimal. An 

increase in commuter traffic is expected during the construction phase, but this increase is expected to be 

minor, as most workers would be onsite prior to peak commuting hours. This impact would fluctuate 

during the peak construction phase. 

Bayou Casotte Energy has indicated that it would consult with state and local transportation 

authorities to determine whether a Maintenance of Traffic Study would be required. We therefore 

recommend that: 

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• Bayou Casotte Energy file with the Secretary the outcome of those consults prior to the 

initiation of construction. 

Operation of the proposed Project would require an estimated 50 employees. The commuting 

activities of these 50 employees would represent a minor increase in area traffic for the life of the Project. 

4.10 CULTURAL RESOURCES 

Section 106 of the NHPA, as amended, requires that the FERC take into account the effects of its 

undertakings (including the issuance of permits or certificates) on properties listed in, or eligible for 

listing in, the NRHP and to provide the ACHP an opportunity to comment on the undertaking. Bayou 

Casotte Energy, as a non-federal party, is assisting the FERC in meeting its obligations under Section 106 

and the implementing regulations in 36 CFR 800. 

4.10.1 Cultural Resources Assessment 

4.10.1.1 LNG Terminal 

Bayou Casotte Energy completed a cultural and architectural resources survey of the 259.4-acre 

proposed LNG terminal site. No previously recorded sites were found within the proposed Project area, 

and no cultural or architectural resources were identified during survey of the proposed LNG terminal 

site. A Cultural Resource Report was submitted to the Mississippi State Historic Preservation Officer 

(SHPO), who agreed with the report’s conclusion that no historic properties would be affected by 

construction (letter of May 17, 2005). 

4.10.1.2 Natural Gas Pipeline System Interconnects 

Detailed engineering was completed for the interconnects in January 2006, and supplemental 

cultural resource field surveys were conducted. An addendum to the Phase I report, was approved on 

May 9, 2006, by the Mississippi Department of Archives and History (MDAH). The report indicated that 

no cultural resources and/or historic standing structures were identified and the extensive deposits of man 

made land and inundated wetlands indicated that no additional testing was necessary. The SHPO 

concurred with the conclusions that impacts to cultural or architectural resources as part of the 

construction and operation of the natural gas pipeline interconnects are not expected. 

4.10.1.3 Dredged Material Placement/Disposal Location(s) 

Currently, Bayou Casotte Energy is not proposing onshore placement of dredged material, with 

the exception of the use of material on the proposed terminal site. No cultural or architectural resources 

were identified during the survey of the proposed LNG terminal site. In the event that additional onshore 

locations are necessary for disposal, additional surveys would be required and results provided to the 

Mississippi Department of Archives and History. Any additional field surveys would require that an 

addendum to the Phase I report be provided to the Mississippi Department of Archives and History for 

review, comment, and approval. 

4.10.1.4 NGL Pipeline 

Detailed engineering was completed for the 12-inch-diameter NGL pipeline route in 

January 2006, and supplemental cultural resource field surveys were conducted for the finalized NGL 

pipeline. Results of the supplemental field surveys were filed in an addendum to the Phase I report and 

were provided to MDAH for review, comment, and approval. The SHPO agreed with the conclusions of 

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the report that assessed the cultural and historical data and found that no impact would be generated by 

the NGL pipeline (letter of May 9, 2006). 

4.10.1.5 Electric Transmission Lines 

Bayou Casotte Energy has not conducted cultural and architectural resources surveys along the 

electric transmission line proposed by Mississippi Power. Mississippi Power will apply for 

environmental permits for construction of the facility separately from the Casotte Landing Project closer 

to the time of construction. Bayou Casotte Energy does not have control over the routing, siting, or 

permitting of this facility. The Phase I report cites a 2000 survey of the Destin Pipeline right-of-way, and 

no cultural or architectural resources of concern were located. Impacts to cultural or architectural 

resources associated with the proposed electric transmission lines are not expected. 

4.10.1.6 Waste Heat Delivery and Cool Water Return System 

Detailed engineering was completed for the Circulation Water System in January 2006, and 

supplemental cultural resource field surveys were conducted for the finalized pipe routes. An addendum 

to the Phase I report was provided to MDAH for review, comment, and approval. Based on current 

approved surveys and historical data, the SHPO concurred that no impacts to cultural or historical 

resources associated with the waste heat delivery and cool water return system are anticipated. 

4.10.1.7 Additional Extra Workspace Areas 

Detailed engineering of additional extra workspace areas associated with finalized natural gas 

system interconnects, the 12-inch-diameter NGL pipeline, and other nonjurisdictional facilities was 

completed in January 2006, and supplemental cultural resource field surveys were conducted for the 

additional extra workspace areas. An addendum to the Phase I report was provided to MDAH for review, 

comment, and approval. The SHPO concurred with the report that no sites or properties listed in or 

eligible for listing in the National Register of Historic Places will be affected (letter of May 9, 2006). 

4.10.1.8 Transit Waterway 

The LNG marine traffic would transit along the waterway from the territorial seas to the berthing 

facility, passing through the Horn Island Pass. In the unlikely event of an LNG spill, the physical 

properties of LNG would limit any potential impacts to cultural resources on either Horn or Petit Bois 

Island. Additional information on the environmental impacts resulting from the transit of the LNG ships 

is provided in Section 4.12.5.3. 

4.10.2 Unanticipated Discovery Plan 

As part of its application and survey reports, Bayou Casotte Energy filed an acceptable 

Unanticipated Discoveries Plan that outlines procedures to be followed in the event that cultural resources 

or human remains are discovered during construction. 

4.10.3 Native American Consultation 

On April 8, 2005, Bayou Casotte Energy sent a consultation letter to the Mississippi Band of 

Choctaw Indians to describe the Project and to provide an opportunity to comment on the proposed 

Project and identify sites or places that might be of religious or cultural significance to the tribe. To date, 

no response has been received. 

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4.10.4 Impact and Mitigation 

We have completed the process of complying with Section 106 of the NHPA the proposed 

Casotte Landing Project. All cultural resources surveys have been completed, and survey results for 

alternative interconnect locations were included in the Phase I report and Supplemental report and was 

submitted to the SHPO. Since no historic or cultural resources were identified there is no need to 

determine eligibility or Project effects. 

4.11 AIR QUALITY AND NOISE 

4.11.1 Air Quality 

4.11.1.1 Regional Climate 

The local climate for the proposed Project area is characteristic of subtropical regions, with short 

mild winters and warm humid summers. The Gulf of Mexico plays an important part in moderating the 

local weather by producing a pronounced sea breeze effect in the summer and tempering the effects of 

polar outbreaks. The prevailing winds are generally from offshore to onshore from the southeast to southsoutheast, except during winter months when passing cold fronts bring prevailing winds from the north to 

north-northeast. Wind speeds average between 7 to 10 miles per hour throughout the year. 

This portion of Mississippi is subject to sever weather. Tropical cyclones (hurricanes) are not 

unusual for the Project area. According to the NOAA Storm Events Database, numerous tornados, 

hurricanes, and tropical storms occurred in Jackson County, Mississippi between 1950 and 2004. Data 

for the recent hurricanes, Rita and Katrina, are not yet available from NOAA. 

According to data obtained from the Office of the Mississippi Climatologist for National Weather 

Service Cooperative Station Pascagoula 3NE for the period of 1971 to 2000, precipitation averages about 

67 inches per year with the most rainfall occurring in July. The mean monthly temperatures in the 

Pascagoula area range from a low of 49.4 °F to a high of 80.8°F, with an average annual temperature of 

about 66°F. 

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 the NAAQS for the following criteria pollutants: nitrogen dioxide (NO2), carbon 

monoxide (CO), ozone (O3), sulphur dioxide (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). 

In 2004, EPA provided designations for a new 8-hour O3 standard. The new 8-hour standard is 

now effective and the 1-hour O3 standard became ineffective after June 15, 2005 in most areas including 

Jackson County, Mississippi. Mississippi has adopted the NAAQS as the ambient air quality standards 

within the State of Mississippi by Regulation APC-S-4; however, this regulation has not been amended to 

reflect the revocation of the 1-hour ozone standard. 

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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 maintained. 

The local Project area is located in the Mobile-Pensacola-Panama City-Southern Mississippi AQCR. 

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”. Jackson County is designated as 

“attainment” or “unclassifiable” for all criteria pollutants.

Air Quality Monitoring and Existing Air Quality 

Air quality monitors are located throughout the state and region for a variety of purposes. The 

nearest monitoring site for NO2, O3, SO2, PM2.5, and PM10 is in Pascagoula, Mississippi. The nearest 

monitoring location for CO is in Mobile, Alabama. The nearest Pb monitoring site is in Pike County, 

Alabama. The available monitoring data are summarized in Table 4.11.1-1 along with the standards 

established under the NAAQS. 

TABLE 4.11.1-1 

National Ambient Air Quality Standards for the Casotte Landing Project 

Pollutant 

Averaging 

Time 

Primary 

Standard (μg/m3) 

Secondary 

Standard (μg/m3) 

Background

(μg/m3) 

Monitoring Station 

Number and Location 

Annual a 80 (0.03 ppm) - 8 28059006 Pascagoula, MS 

24-hour b 365 (0.14 ppm) - 52 28059006 Pascagoula, MS 

SO2

3-hour b - 1,300 (0.5 ppm) 121 28059006 Pascagoula, MS 

Annual a PM10 50 50 20 28059006 Pascagoula, MS 

24-hour b 150 150 51 28059006 Pascagoula, MS 

Annual c PM2.5 15 15 15.2 28059006 Pascagoula, MS 

24-hour d 65 65 32 28059006 Pascagoula, MS 

8-hour b CO 10,000 (9 ppm) - 1,947 010973101 Mobile, AL 

1-hour b 40,000 (35 ppm) - 2,290 010973101 Mobile, AL 

O3 8-hour e 157 (0.08 ppm) 157 (0.08 ppm) 165 28059006 Pascagoula, MS 

NO2 Annual a 100 (0.05 ppm) 100 (0.05 ppm) 15 28059006 Pascagoula, MS 

Pb Quarter a 1.5 - - 

a

 Arithmetic mean. 

b

 High second high. 

c

 3-year average of annual arithmetic mean. 

d

 3-year average of the 98th percentile of 24-hour values. 

e

 3-year average of 4th highest 8-hour values. 

ug/m3 micrograms per cubic meter 

ppm parts per million 

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As indicated previously and demonstrated by the local monitoring data, the State of Mississippi is 

in attainment of the NAAQS for all criteria pollutants. No background concentration for Pb is identified 

in Table 4.11.1-1. Lead is usually monitored only in locations that have a specific source of lead 

emissions. The nearest ambient monitor for lead is in Pike County, Alabama where a secondary lead 

smelter is located. The ambient Pb concentrations monitored in Pike County, Alabama would not be 

representative of ambient conditions in Jackson County, Mississippi. 

4.11.1.3 Regulatory Requirements for Air Quality 

The proposed Project is potentially subject to a variety of federal, state, and local regulations 

pertaining to the construction or operation of air emission sources. The MDEQ has the primary 

jurisdiction over air emissions produced by the proposed LNG terminal. The MDEQ enforces its own 

regulations as well as EPA’s federal requirements. The following sections summarize the applicability of 

various MDEQ and federal regulations. Jackson County does not have any additional air permit 

requirements beyond the MDEQ and federal programs. 

Jackson County is designated as in attainment for all of the NAAQS. However to avoid 

exceedances of the O3 standards, 40 CFR 80.27 mandates using less volatile gasoline from May through 

September. 

Federal Air Quality Requirements 

The CAA, 42 USC 7401 et seq., as amended in 1977 and 1990, and 40 CFR Parts 50 through 99 

are the basic federal statutes and regulations governing air pollution in the United States. The following 

federal requirements have been reviewed for applicability to the proposed Project. 

New Source Review/Prevention of Significant Deterioration

Separate preconstruction review procedures have been established for projects that are proposed 

to be built in attainment areas versus nonattainment areas. The preconstruction review process for new or 

modified major sources located in attainment areas is called New Source Review (NSR) and may include 

a Prevention of Significant Deterioration (PSD) review. This review process is intended to keep new air 

emission sources from causing existing air quality to deteriorate beyond acceptable levels codified in the 

federal regulations. 

The proposed Project is located in a designated attainment area for the NAAQS. Therefore, new 

major sources and major modifications in this area are subject to the PSD rule. The PSD rule defines a 

major source as any source with a potential to emit 100 tons per year (tpy) or more of any criteria 

pollutant for source categories listed in 40 CFR 52.21(b)(1)(i) or 250 tpy or more of any criteria pollutant 

for source categories that are not listed. Because the proposed Project is not one of the named sources, 

the PSD threshold for the proposed Project is 250 tpy. Sources which exceed the 250 tpy threshold are 

then subject to a PSD review and PSD increments which are used to define the maximum allowable 

pollutant concentration increases over baseline concentrations that are allowed in attainment areas. The 

Class I and Class II PSD increments are listed in Table 4.11.1-2. A summary of the stationary source 

emissions for the LNG terminal and unloading is included in Table 4.11.1-4 which shows that no 

pollutant is emitted at the 250 tpy level and Bayou Casotte Energy is not a major PSD source and is not 

subject to a PSD review. 

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TABLE 4.11.1-2 

PSD Class I and Class II Increments 

Pollutant Averaging Time Class I Increment 

(μg/m3) 

Class II Increment 

(μg/m3) 

Annual 2 20 

24-hour 5 91 

SO2

3-hour 25 512 

PM10 Annual 4 17 

24-hour 8 30 

NO2 Annual 2.5 25 

__________ 

Source: : 40CFR52.21(c) 

One additional factor considered in the PSD permit review process is potential impacts on 

protected Class I areas. If a project is located within 100 kilometers of a federal Class I area, additional 

modeling analysis may be required to determine the potential impacts on the area. The proposed project 

is within 47 kilometers of the Breton National Wildlife Refuge (BNWR), a federally designated Class I 

area. 

Although the proposed project would not be subject to a PSD review and would also not be 

required to perform an analysis on the Class I area, FERC staff required Chevron to conduct a refined 

Class I and Class II modeling analysis to evaluate the potential impacts of the proposed project using a 

model suggested for use in complex coastal environments similar to the proposed project location. 

Section 4.11.1.4 includes a discussion of the refined Class I and Class II modeling analyses performed by 

Bayou Casotte Energy to assess impacts associated with operation of the proposed project as request by 

the Commission. 

New Source Performance Standards

New Source Performance Standards (NSPS), codified at 40 CFR 60 establish requirements for 

new, modified, or reconstructed units in specific source categories. NSPS requirements include emission 

limits, monitoring, reporting, and recordkeeping. The following NSPS requirements were identified as 

potentially applicable to the specified sources at the facility. 

Subpart Db of 40 CFR 60, Standards of Performance for Industrial-Commercial-Institutional 

Steam Generating Units, applies to fuel-fired steam-generating units with a heat input capacity of greater 

than 100 million btu/hour (MMBtu/hr). The definition of an applicable unit includes sources that produce 

steam or heat water or any other heat transfer medium. The process heaters, which would be used to 

vaporize the LNG, would have a capacity of 280 MMBtu/hr each and would burn natural gas to heat an 

intermediate fluid (glycol). The heaters are therefore subject to Subpart Db. Subpart Db requirements 

include a NOx emission limit of 0.1 or 0.2 pound per million British thermal units (lb/MMBtu), 

installation and operation of a continuous emissions monitor, as well as associated reporting and 

recordkeeping. 

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Subpart Kb of 40 CFR 60, Standards of Performance for Volatile Organic Liquid Storage Vessels

lists affected emission sources as storage vessels containing volatile organic liquids (VOLs). Regulatory 

applicability is dependent on the construction date, size, vapor pressure, and contents of the storage 

vessel. Subpart Kb applies to new tanks, unless otherwise exempted, that have a storage capacity 

between 75 m3 (19,813 gallons) and 151 m3 (39,890 gallons) and contain volatile organic compounds 

(VOCs) with a maximum true vapor pressure greater than or equal to 15.0 kilopascals (kPa). Subpart Kb 

also applies to tanks that have a storage capacity greater than or equal to 151 m3 and contain VOCs with a 

maximum true vapor pressure greater than or equal to 3.5 kPa. Each of the LNG storage tanks would 

have a capacity of 160,000 m3, which meets the volume criteria for Subpart Kb. The LNG is considered a 

VOL because a small portion of the LNG would consist of VOCs. The vapor pressure of the VOC 

(assumed to be propane) that would be stored in the LNG tanks is about 0.0007 kPa at the proposed 

storage temperature of -270°F (Perry and Green, 1997). Therefore, the proposed LNG storage tanks are 

not subject to NSPS Subpart Kb. The proposed LNG Terminal would also have two diesel fuel storage 

tanks. The largest diesel storage tank would be about 7,450 gallons in capacity so these tanks would also 

not be subject to NSPS Subpart Kb. 

Proposed New Source Performance Standards (NSPS) – On July 11, 2005, EPA proposed a new 

NSPS for compression ignition (CI) internal combustion engines (ICE). Under the proposed rule, 

beginning on October 1, 2007, diesel fuel will be restricted to 500-ppm sulfur and 15-ppm sulfur by 

October 1, 2010. Also, any CI ICEs would comply with the model year requirements described in the 

final rule. When the rule becomes finalized, the proposed Project would comply with any applicable 

standards of the final rule. 

Subpart KKK of 40 CFR 60, Standards of Performance for Equipment Leaks of VOC from 

Onshore Natural Gas Processing Plants applies to a natural gas processing plant engaged in the 

extraction of natural gas liquids from field gas, fractionation of mixed natural gas liquids to natural gas 

products, or both. The proposed project includes an NGL plant (non-jurisdictional facility) which would 

be subject to this subpart and therefore would meet the requirements of this subpart and would be 

included as part of the air permit application. This subpart would only apply to the NGL plant. 

National Emissions Standards for Hazardous Air Pollutants

The National Emissions Standards for Hazardous Air Pollutants (NESHAP), codified in 40 CFR 

Parts 61 and 63, regulates hazardous air pollutant (HAP) emissions. Part 61 was promulgated prior to the 

1990 Clean Air Act Amendments (CAAA) and regulates only eight types of hazardous substances 

(asbestos, benzene, beryllium, coke oven emissions, inorganic arsenic, mercury, radionuclides, and vinyl 

chloride). 

The 1990 CAAA established a list of 189 HAPs, resulting in the promulgation of Part 63. 

Part 63, also known as the Maximum Achievable Control Technology standards, regulates HAP 

emissions from major sources of HAP emissions and specific source categories that emit HAPs. Part 63 

defines a major source of HAPs as any source that has the potential to emit 10 tpy of any single HAP or 

25 tpy of HAPs in aggregate. 

LNG storage and processing facilities do not fall under one of the source categories regulated by 

Part 61; therefore, the requirements of Part 61 are not applicable to the Project. Part 63 establishes HAP 

emission standards for marine vessel loading operations (Subpart Y); oil and gas production facilities 

(Subpart HH); natural gas transmission storage facilities (Subpart HHH); industrial, commercial, and 

institutional boilers and process heaters (Subpart DDDDD); and reciprocating internal combustion 

engines (Subpart ZZZZ). These subparts establish requirements for major sources of HAPs only. HAP 

emissions (in aggregate) from the proposed LNG Terminal would be about 2.7 tpy. The single largest 

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HAP emitted by the Project terminal would be hexane at a rate of approximately 2.0 tpy. LNG carrier 

unloading would result in emission of 1.9 tpy of aggregate HAP emissions including 1.1 tpy of 

formaldehyde. Total stationary source aggregate HAP emissions would be 4.6 tpy; therefore, Bayou 

Casotte Energy would not be a major HAP source and no NESHAPs are applicable to the project. 

Chemical Accident Prevention Provisions

The chemical accident prevention provisions, codified in 40 CFR 68, are federal regulations 

designed to prevent the release of hazardous materials in the event of an accident and minimize potential 

impacts if a release does occur. The regulations contain a list of substances and threshold quantities for 

determining applicability to stationary sources. If a stationary source stores, handles, or processes one or 

more substances on this list in a quantity equal to or greater than specified in the regulation, the facility 

must prepare and submit a risk management plan (RMP). If a facility does not have a listed substance onsite, or the quantity of a listed substance is below the applicability threshold, the facility does not have to 

prepare an RMP. In the latter case the facility still must comply with requirements of the general duty 

provisions in Section 112(r)(1) of the 1990 CAAA if there is any regulated substance or other extremely 

hazardous substance on-site. 

Stationary sources are defined in 40 CFR 68 as any buildings, structures, equipment, installations, 

or substance-emitting stationary activities which belong to the same industrial group, which are located 

on one or more contiguous properties, which are under the control of the same person (or persons under 

common control), and from which an accidental release may occur. However, the definition also states 

that the term stationary source does not apply to transportation, including storage incidental to 

transportation, of any regulated substance or any other extremely hazardous substance. The term 

transportation includes transportation subject to oversight or regulation under 49 CFR 192, 193, or 195 or 

a state natural gas or hazardous liquid program for which the state has in effect a certification to DOT 

under 49 USC Section 60105. Based on these definitions, the only substance that would be potentially 

applicable to the RMP regulation is the LNG that is stored incidental to transportation. Therefore, an 

RMP is not required for this facility. However, the facility would have to comply with the general duty 

provisions of the 1990 CAAA as discussed above. 

Title V Operating Permit

Title V of the CAA requires states to establish an air operating permit program. The 

requirements of Title V are outlined in 40 CFR 70 and the permits required by these regulations are often 

referred to as Part 70 permits. Mississippi has incorporated this program in Regulation APC-S-6. 

If a facility’s potential to emit exceeds the major source threshold for a criteria pollutant or HAP, 

the facility is required to obtain a Title V operating permit. The major source threshold level for an air 

emission source in Jackson County is 100 tpy for any criteria pollutants (PM10, PM2.5., SO2, NOx, VOC, or 

CO), 10 tpy of any single HAP, or 25 tpy of all HAPs in aggregate. The stationary source potential to 

emit for the criteria pollutants NOx, CO, and SO2 are anticipated to be above the major source thresholds 

when LNG carrier unloading emissions are included (see Table 4.11.1-4). Therefore, the proposed 

facility is required to obtain a Title V operating permit. 

General Conformity

40 CFR parts 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. The 

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proposed LNG terminal would be located in Jackson County, which is in attainment of the NAAQS for 

all pollutants. Therefore, the general conformity requirements do not apply to the proposed Project. 

Applicable State Air Quality Requirements 

The MDEQ is the air permitting authority for the proposed Project. The MDEQ's air quality 

regulations are codified in Regulations APC-S-1 through APC-S-10. These regulations incorporate the 

federal requirements from 40 CFR Parts 50 through 99 and establish permit review procedures for all 

facilities that emit pollutants to the ambient air. Any new facility that may emit air contaminants is 

required to obtain a preconstruction permit. As indicated above, the facility is not subject to the PSD 

permitting requirements but is subject to the Title V permitting requirements; therefore, the facility would 

be required to obtain a state construction permit with federally enforceable limits. The MDEQ permit 

would require compliance with all applicable state and federal air regulations. 

Under federal regulations (40 CFR Part 70.8(b)), the air permitting authority shall provide any 

affected state a copy of the draft operating permit for review and comment. An affected state is one 

whose air quality may be affected and that is contiguous to the state in which a title V operating permit, 

permit modification, or permit renewal is being proposed or one that is within 50 miles of the permitted 

source. The proposed LNG terminal would be located within 50 miles of the Louisiana and Alabama 

borders; therefore, the Louisiana Department of Environmental Quality and the Alabama Department of 

Environmental Management would be given the opportunity to review and comment on Bayou Casotte 

Energy’s draft operating permit prior to issuance by the MDEQ. 

A summary of the state air regulations potentially applicable to the project is provided below. 

APC-S-1 – Air Emission Regulations for the Prevention, Abatement, and Control of Air Contaminants

APC-S-1 includes specifications for specific pollutants, hazardous air pollutants, certain specific 

sources of pollutants, notification of emission events, and stack heights. Section 3 contains criteria for 

sources of particulate matter, including opacity limitation, open burning prohibition, and nuisance 

prohibition. The diesel and natural gas fueled equipment is expected to comply with the 40 percent 

opacity standard. Section 4 contains criteria for SO2 emissions. The natural gas and low sulfur diesel 

burning equipment are expected to comply with the 4.8 pound SO2/million btu standard. APC-S-1 also 

incorporates by reference the federal NSPS program. As discussed previously, the terminal’s MDEQ 

permit would require compliance with all applicable federal regulations and state air regulations. Specific 

requirements and compliance methods are described below. 

APC-S-2 – Permit Regulations for the Construction and/or Operation of Air Emissions Equipment

APC-S-2 contains the requirements for obtaining permits prior to constructing new equipment 

and for obtaining state permits to operate, including public notice and participation requirements. The 

Project would obtain the required permits prior to commencing construction. 

APC-S-3 – Mississippi Regulations for the Prevention of Air Pollution Emergency Episodes 

APC-S-3 defines air pollution alerts, warnings, and emergencies, and establishes requirements for 

operators of certain sources to prepare plans for responding to these three levels of air pollution episodes. 

The Project would prepare an Emission Control Action Program in accordance with Section 4. 

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APC-S-4 – Mississippi Ambient Air Quality Standards

APC-S-4 adopts the federal NAAQS as the Mississippi Ambient Air Quality Standards. The 

Project would demonstrate through air dispersion modeling that emissions from the proposed action 

would not cause or contribute to a violation of the NAAQS. 

APC-S-5 – Mississippi Regulations for the Prevention of Significant Deterioration of Air Quality

APC-S-5 essentially adopts the federal PSD program, with changes to refer to the Mississippi 

program rather than the federal program. The Project would not be a PSD source. 

APC-S-6 – Air Emissions Operating Permit Regulations for the Purposes of Title V of the Federal CAA

APC-S-6 essentially adopts the federal Title V program, with changes to refer to the Mississippi 

program rather than the federal program. The Project would be subject to Title V and would obtain the 

required permit within the timeframe specified by APC-S-6. 

APC-S-7 - Acid Rain Program Permit Regulations for Purposes of Title IV of the Federal Clean Air Act

APC-S-7 essentially adopts the federal acid rain program, with changes to refer to the Mississippi 

program rather than the federal program. The Project would not be subject to the acid rain program. 

APC-S-8 – Air Toxics Regulations

APC-S-8 essentially adopts the federal case by case Maximum Achievable Control Technology 

(MACT) determination provisions at 40 CFR 63 Subpart B, and the federal chemical accident prevention 

program at 40 CFR 68, with changes to refer to the Mississippi programs rather than the federal 

programs. The MACT program and chemical accident prevention program are discussed in the federal 

rules review section of this report. 

APC-S-9 – Regulations for Lead Based Paint Activities

APC-S-9 governs training and certification of individuals who provide lead based paint activity 

services, and work practices involving target housing and child-occupied facilities. This rule does not 

apply to the Project. 

APC-S-10 –Regulations for the Accreditation and Certification of Asbestos Abatement Personnel

Asbestos will not be installed at the Project. This rule does not apply. 

4.11.1.4 Air Quality Impacts and Mitigation 

Construction Air Pollutant Emissions 

The proposed Project would generate air emissions during the construction phase. The 

construction activities that would generate air emissions include: 

• site preparation (earthmoving); 

• operation of vehicles and trucks during construction; 

• operation of marine vessels during construction; 

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• installation of terminal components; 

• relocation of refinery Berths 6 and 7; 

• dock construction; 

• hurricane levee construction; 

• pipeline and pipeline interconnection installation; and 

• employee commuting trips. 

Site preparation would include stripping the top layer of earth, removal of earth from high 

elevation areas to level the terminal site to finished grade, constructing the LNG storage tank dike, and 

similar site preparation for other facilities. Site preparation activities would generate fugitive dust (PM10) 

from earthmoving and movement of construction equipment over unpaved surfaces and tailpipe emissions 

from construction equipment and vehicle engines. The construction equipment and vehicles would be 

powered by internal combustion engines that would generate PM10, SO2, NOx, VOC, and CO emissions. 

Site preparation equipment would include cranes, trucks, bulldozers, front-end loaders, backhoes, 

compactors, graders, dump trucks, and other mobile construction equipment. 

The installation of terminal components would include installation of unloading dock pile caps 

and beams, deck slabs, mooring and breasting dolphin caps, LNG unloading and vapor return arms, major 

mechanical equipment, and piping and instrumentation, as well as construction of LNG storage tanks, 

foundations, pipe racks, and buildings. The terminal site construction equipment would include cranes, 

backhoes, pile drivers, welders, and generators, which would generate tailpipe and fugitive dust emissions 

similar to the site preparation activities. 

The proposed Project would include excavating and dredging a marine slip initially to 46 feet 

below MLLW. Approximately 1 million cubic yards of material would be excavated and used in the site 

grading, LNG containment system, and hurricane levee construction. Approximately 3.5 million cubic 

yards of material would be dredged. The dredged material would be placed in bottom dump scows for 

transport to placement areas. The emissions generated by these activities would be predominantly 

combustion emissions from the construction equipment and vehicle engines. The construction equipment 

would include a hydraulic dredge, tugboats, a workboat, cranes, excavator, barge, bulldozers, and trucks. 

Site truck traffic and worker commuter vehicles would generate fugitive dust from travel on 

paved and unpaved surfaces as well as tailpipe emissions. The proposed LNG terminal site construction 

would require a workforce between 400 and 600 over a period of 36 months. The internal combustion 

engines for most of the construction equipment would burn diesel fuel. Some of the pickup trucks and 

most of the commuter vehicles would likely burn gasoline. 

Air emissions would also be generated during construction of the proposed natural gas sendout 

pipeline. The pipeline construction activities would take place over a period of about six months. Similar 

to the terminal construction emissions, the pipeline construction activities would generate fugitive dust 

from clearing, trenching, backfilling, grading, and traffic on paved and unpaved areas, as well as 

combustion emissions from construction equipment, commuter trips, and supply vehicles. The internal 

combustion engines powering most of the pipeline construction equipment and vehicles would burn diesel 

fuel and the remaining vehicles would burn gasoline. Equipment that would be used for the pipeline 

construction activities would include earthmoving equipment, pickup trucks, compressors, pumps, 

trenchers, stringing trucks, welding rigs, and equipment for restoring disturbed areas. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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The emissions from construction activities are not part of the permitting requirements for the 

LNG terminal. Nevertheless, emissions from the construction activities are discussed above to assist in 

assessing the environmental issues associated with the Project. Estimates were based on EPA emission 

factors for stationary engines (for construction equipment and commuter vehicle tailpipe emissions), EPA 

estimation methods for vehicle travel on paved roads (for dust generated by on-site truck and vehicle 

traffic and worker commuting trips), and EPA estimation methods for concrete batch plants. SO2

emission factors were based on appropriate chapters of EPA’s AP-42. AP-42 assumes that diesel fuel 

contains approximately 0.3 to 0.5 percent sulfur by weight. Bayou Casotte Energy indicated that it would 

use the diesel fuels that are commercially available in the Project area at the time of construction. These 

diesel fuels are expected to contain less than 0.05 percent sulfur by weight based on current EPA fuel 

standards. Therefore, SO2 emissions provided by Bayou Casotte Energy are conservative. The emissions 

from construction activities would include PM2.5, PM10, NOx, CO, SOx, VOCs, and HAPs. The criteria 

pollutant emissions from construction are summarized in Table 4.11.1-3. It is conservatively assumed 

that all PM10 is less than 2.5 microns in diameter; therefore, the PM10 emissions are equal to the PM2.5

emissions. 

TABLE 4.11.1-3 

Estimated Emissions from LNG Terminal and Pipeline Interconnect Construction 

Emission Source PM10/PM2.5 

(tons) 

NOx

(tons) 

CO 

(tons) 

SOx

(tons) 

VOC 

(tons) 

LNG Terminal and Pipeline 

Marine construction equipment 8.18/8.18 130.68 361.84 16.25 24.28 

Mobile onshore construction equipment 28.90/28.90 407.50 685.69 26.92 59.73 

Fugitive dust emissions from worker commuting 10.98/0.96 0 0 0 0 

Vehicle emissions from worker commuting 0.03/0.03 0.51 20.41 0.03 1.00 

Fugitive dust from dredging 1.38/1.38 0 0 0 0 

Fugitive dust from construction vehicles 9.78/1.50 0 0 0 0 

Fugitive dust from mobile construction equipment 2160/2160 0 0 0 0 

Concrete Plants 16.39/16.39 0 0 0 0 

Total Construction Emissions 2236/2217 538.69 1067.94 43.20 85.01 

These emissions would be spread over a period of about 36 months and would increase the 

pollutant concentrations in the vicinity of the project; however, their effect on ambient air quality would 

vary with time due to the construction schedule, the mobility of the sources, and the variety of emission 

sources. . The emissions would cease at completion of the proposed Project. Fugitive dust could have an 

impact in the immediate vicinity of the construction activity and would cease once construction in a 

particular area is complete. To ensure that measures are implemented to reduce nuisance dust emission 

during construction, we recommend that: 

• Bayou Casotte Energy prepare a Fugitive Dust Control Plan that specifies the following: 

a. The precautions that would be taken to minimize fugitive dust emissions from 

construction activities and when/how the measures would be applied; 

b. the individuals with the authority to determine if/when water needs to be reapplied 

for dust control; and 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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c. the individuals with the authority to stop work if the contractor does not comply 

with dust control measures. 

This plan should be filed with the Secretary for review and written approval of the 

Director of OEP prior to the start of construction activities. 

Air Pollutant Emissions from Operation 

LNG Terminal Sources

New air emissions sources associated with operation of the proposed Project include: 

• two 280 MMBtu/hr natural gas-fired heaters; 

• one 1,500 kw natural gas or diesel-fueled emergency generator; 

• one 1,750 hp boil off gas compressor engine; 

• three 550 hp diesel-fueled firewater pumps; 

• one high-pressure emergency flare stack with pilots and purge; 

• one 7,450-gallon diesel day tank for the emergency generator; 

• three 600-gallon diesel day tanks for the emergency firewater pump engines; 

• one 2,300-gallon oily water surge drum; 

• fugitive emission sources (valves, flanges, sampling ports, and marine vessel offloading 

equipment); 

• three 160,000 m3 full-containment LNG storage tanks; and 

• LNG ships and tugboats. 

Table 4.11.1-4 summarizes the air emissions that would be generated by stationary sources as 

well as mobile sources at the LNG terminal. 

Unregulated pollutants such as methane (primary component of LNG) would be emitted during 

operation of the LNG terminal. Some of the LNG would vaporize during storage or transfer during LNG 

ship unloading. The vaporized LNG is referred to as boil-off gas (BOG). The BOG generated by the 

LNG terminal during operation would be minimized by using a closed system to capture the vapor which 

would be pumped into the LNG ship during LNG-offloading or condensed in a direct contact condenser 

with LNG as the contact liquid and then combined with the sendout natural gas prior to the sendout 

pumps. 

Bayou Casotte Energy would minimize air emission from the proposed stationary sources through 

the use of clean fuel (natural gas and low sulfur diesel oil), the employment of BMPs for operation and 

maintenance procedures, and limiting annual hours of operation from the diesel-fired units. No 

operational emissions from the sendout pipeline would be regulated by the MDEQ or EPA air quality 

regulations. Operational emissions would be limited to blowdown emissions that would occur during 

emergency situations and fugitive emissions during operation. Blowdowns would rarely occur and 

fugitive emissions would be negligible due to the small amount of natural gas emitted and the small 

fraction of VOCs contained in the natural gas. Therefore, these emissions would not have a significant 

effect on air quality. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 4.11.1-4 

Estimated Stationary Source and Mobile Marine Vessel Emissions for 

Operation of Casotte Landing LNG Terminal 

PM10/PM2.5 NOx CO SO2 VOC HAP 

Emission 

Source 

(lb 

/hr) (tpy) 

(lb 

/hr) (tpy) 

(lb 

/hr) (tpy) 

(lb 

/hr) (tpy) 

(lb 

/hr) (tpy) 

(lb 

/hr) (tpy) 

Stationary Sources

Heaters 4.09 7.37 17.52 31.54 4.46 8.03 0.32 0.58 2.96 5.33 1.0 1.80 

Pipeline 

Compressor 0 0 51.91 12.98 7.09 1.77 0.01 0.00 1.50 0.38 0.92 0.23 

Emergency 

Generator 0.84 0.21 48.29 12.07 15.09 3.77 0.80 0.20 2.66 0.66 0.11 0.03 

Emergency 

Fire Pumps 3.63 0.11 51.15 1.53 11.02 0.33 0.02 0.00 4.15 0.12 0.01 Neg. 

Flare 

Pilots/Purge 0.18 0.77 0.12 0.51 0.63 2.78 0 0 0.11 0.47 Neg. 0.03 

Flare 1120 12.03 740 7.94 4024 43.21 135 0.07 685 7.36 36.0 0.38 

Fugitive 

Emissions 0 0 0 0 0 0 0 0 3.70 16.22 Neg. Neg. 

Hydrocarbon 

Tanks 0 0 0 0 0 0 0 0 Neg. Neg. Neg. Neg. 

LNGC 

Unloading 9.60 13.12 44.40 56.65 6.50 8.26 22.20 44.85 2.40 3.19 1.6 1.90 

Total 

Stationary 

Source 

1138.3 33.6 953.4 123.2 4068.8 68.2 158.4 45.7 702.5 33.7 39.6 4.4 

Mobile Sources

LNGC 

Transit 

/Hotelling 

5.54 4.86 24.14 21.17 3.52 3.09 19.04 16.70 1.36 1.19 - - 

Tugboat 

Operations 0.62 0.54 29.61 25.97 3.84 3.37 5.19 4.56 1.40 1.22 - - 

Mobile 

Rolling Stock 1.41 0.65 19.92 9.19 131.50 116.32 1.32 0.61 7.23 5.79 - - 

Total Mobile 

Source 7.6 6.1 73.7 56.3 138.9 122.8 25.6 21.9 10.0 8.2 - - 

Total 

Project 

Sources 

1145.9 39.7 1026.1 179.5 4207.7 191.0 184.0 67.6 712.5 41.9 - - 

____________ 

lb/hr pounds per hour 

tpy tons per year 

Neg. negligible 

During operating of the project, air emissions from LNG marine traffic and other project-related 

vessels would occur along the entire waterway from the territorial seas to the ship berth. The impacts of 

the LNG marine traffic and other marine vessels within state waters are discussed above under the 

emissions inventories and below under the operational impact assessment. During transit in federal and 

International waters, the LNG ships would usually burn boil-off gas from vaporized LNG. The boil-off 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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gas (or natural gas) burned during ship transit is a “cleaner burning” fuel wit lower emissions than the 

heavy weight fuel typically burned during maneuvering, hotelling, and unloading operations while 

coming into and out of port. The operation of the LNG ships in transit outside of state waters would be 

moving at faster speeds and would be in a localized area for a shorter time period, and would be operating 

using a “cleaner burning” fuel than the transit within state waters. During times when operating off of 

boil-off gas is not feasible, the ships would use heavy fuels. The emissions to any one localized area 

during ship transit outside of state waters would be temporary and transient and would be occurring at 

distances allowing for considerable dispersion before reaching any sensitive receptors; therefore, air 

emissions from ship transit are not expected to result in a significant impact on air quality. 

Operational Impact Assessment

In order to provide a more thorough evaluation of the potential impacts on air quality in the 

vicinity of the proposed project, the FERC asked Bayou Casotte Energy to conduct a quantitative 

assessment of project air emissions. The assessment included air dispersion modeling analyses to predict 

off-site (i.e., ambient) concentrations in the vicinity of the project for PM10, SO2, NO2, and CO resulting 

from the proposed emissions associated with operation of the project for comparison to appropriate 

federal air quality standards. A summary of the methodology and results of the Class I and Class II 

analyses is provided below. 

Impacts were predicted at the Breton NWR Class I area and in the Class II area surrounding the 

LNG terminal. The modeling was conducted using the CALPUFF model with a 3-year meteorological 

data set (2001 through 2003) previously approved by state and federal agencies for modeling sources in 

this region. CALPUFF is an advanced regulatory guideline model approved by the EPA for assessing 

coastline effects, overwater transport, and other non-steady-state effects that significantly contribute to the 

downwind dispersion of pollutants being emitted from sources such as the proposed LNG terminal. Class 

I impacts were also evaluated using Visibility Improvement State and Tribal Association of the Southeast 

(VISTAS) meteorological data, and in a manner consistent with the August 2006 VISTAS/BART 

Protocol. Bayou Casotte Energy evaluated impacts for three scenarios for the Class II areas and the most 

conservative of these three scenarios for the Class I area: 

• (Scenario A) Terminal Emissions only (project emissions from sources that would be under 

the direct control of Bayou Casotte Energy including emissions from stationary sources). 

• (Scenario B) Terminal emissions plus unloading emissions from the LNG carriers 

• (Scenario C) Terminal emissions plus unloading emissions plus all other mobile sources 

(LNG carriers, working tugs, Coast Guard escort boats, etc.) operating within a moored 

safety/security zone defined by the Commission as an area extending 500 yards in all 

directions from the area occupied by a typical LNG carrier at berth. 

Predicted impacts on Class II areas were compared to Class II SILs and the results were added to 

the background value and compared to the NAAQS that have been defined by the EPA for SO2, PM10, 

NO2, and CO. Table 4.11.1-5 presents the modeled SO2, PM10, NO2, and CO Class II impacts resulting 

from the project. 

Pollutant impacts presented in Table 4.11.1-5 resulting from one or more of the three scenarios 

evaluated were predicted to exceed their applicable SILs, except for annual PM10, 1-hour CO, and 8-hour 

CO. Since several pollutant impacts for some scenarios exceeded their applicable SILs, this would 

normally trigger further evaluation including other sources in the area. For the pollutants that exceeded 

their applicable SILs, a cumulative impacts evaluation was conducted and the results of this analysis are 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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presented in Section 4.13.9 However, when the predicted impacts are added to available monitored 

background concentrations in the vicinity of the proposed project, none of the impacts would exceed the 

NAAQS, which supports the conclusion that NAAQS compliance would be protected. 

TABLE 4.11.1-5

Summary of Modeled Class II Area Impacts a

Scenario Pollutants 

Averaging 

Period 

Significant 

Impact 

Level 

(μg/m3) 

Year 2001

Modeled 

Impact 

(μg/m3) 

Year 2002

Modeled 

Impact 

(μg/m3) 

Year 2003

Modeled 

Impact 

(μg/m3) 

Background 

Value a 

(μg/m3) 

NAAQS 

(μg/m3) 

3-hour 25 2.24 2.4 2.13 121 1,300 

24-hour 5 0.2 0.22 0.21 52 365 

SO2

Annual 1 0.007 0.009 0.007 8 80 

PM10 24-hour 5 2.6 2.83 2.71 51 150 

Annual 1 0.11 0.12 0.10 20 50 

NO2 Annual 1 0.65 17.3 15.8 15 100 

1-hour 2,000 268.81 299.99 287.34 2,290 40,000 

A 

CO 

8-hour 500 25.70 22.11 20.49 1,947 10,000 

3-hour 25 115.61 117.88 123.52 121 1,300 

24-hour 5 55.00 56.98 54.30 52 365 

SO2

Annual 1 1.92 2.60 2.03 8 80 

PM10 24-hour 5 16.08 16.66 15.87 51 150 

Annual 1 0.62 0.84 0.66 20 50 

NO2 Annual 1 2.75 3.67 2.89 15 100 

1-hour 2,000 268.81 299.99 287.34 2,290 40,000 

B 

CO 

8-hour 500 25.70 22.11 21.31 1,947 10,000 

3-hour 25 157.16 160.25 167.91 121 1,300 

24-hour 5 75.47 78.20 74.52 52 365 

SO2

Annual 1 2.73 3.65 2.85 8 80 

PM10 24-hour 5 22.04 22.84 21.76 51 150 

Annual 1 0.84 1.13 0.89 20 50 

NO2 Annual 1 4.38 5.38 4.35 15 100 

1-hour 2,000 269.04 299.99 287.34 2,290 40,000 

C 

CO 

8-hour 500 28.57 26.33 29.00 1,947 10,000 

_____________________ 

a

 Background values were obtained from the EPA AIRDATA database (http://www.epa.gov/oar/data/geosel.html) as 

follows: 

- Annual values based on maximum value from 3 most recent years of available data. 

- Short-term values based on H2H value from 3 most recent years of available data. 

μg/m3 micrograms per cubic meter 

Bayou Casotte Energy also modeled emissions impacts on the Class I area at BNWR. Class I 

impacts were evaluated under Scenario C only (the worst case scenario involving all potential sources). 

Predicted impacts on the BNWR Class I area were compared to Class I SILs defined by the EPA for SO2, 

PM10, and NO2, and predicted visibility impacts and predicted nitrogen and sulfur deposition were 

compared to applicable thresholds. Visibility impacts were assessed using the procedures in the Best 

Available Retrofit Technology (BART) program. Results of the analysis are presented in Table 4.11.1-6 

through Table 4.11.1-8. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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TABLE 4.11.1-6 

Class I Analysis – Primary and Secondary Emission Sources 

Pollutant Averaging

Period 

Maximum 

Concentration 

(μg/m3) 

SIL 

PM10 24-hour 0.106 0.3 

PM10 Annual 0.002 0.2 

SO2 3-hour 0.944 1.0 

SO2 24-hour 0.178 0.2 

SO2 Annual 0.003 0.1 

NO2 Annual 0.006 0.1 

Results for each pollutant and averaging period were less than the respective SILs and no further 

modeling was necessary to demonstrate that the project would have no significant impacts on the NAAQS 

at BNWR. 

Table 4.11.1-7 presents the results of the visibility analysis and Table 4.11.1-8 presents the results 

of the deposition analysis. The years 2001, 2002, and 2003 were considered in the analysis. Bayou 

Casotte Energy used the CALPUFF model in a manner consistent with the VISTAS/BART approach for 

determining visibility impacts. 

TABLE 4.11.1-7 

Class I Visibility Impairment Analysis 

Statistic 2001 2002 2003 

Days >= 5% 1 0 0 

Days >= 10% 0 0 0 

Max. % Change 5.28 4.01 4.31 

8th High % Change 2.38 1.81 2.31 

One day with visibility impact greater than 5% was indicated in 2001 and no days with greater 

than 5% impact were indicated in 2002 or 2003. Based on the VISTAS/BART approach the 8th high 

percent change, there are no days predicted with 5% impacts. These results indicate that emissions from 

all proposed sources would not significantly impact visibility at BNWR. 

TABLE 4.11.1-8 

Class I Deposition Analysis 

Pollutant 2001 

(kg/ha/yr) 

2002 

(kg/ha/yr) 

2003 

(kg/ha/yr) 

Threshold Value 

(kg/ha/yr) 

Nitrogen 5.51E-04 4.14E-04 4.26E-04 1.00E-02 

Sulfur 2.29E-03 1.88E-03 1.68E-03 1.00E-02 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Deposition rates for both nitrogen and sulfur are below the US Forest Service thresholds. 

Depositional impacts from all proposed sources would not be significant at BNWR. 

4.11.2 Noise 

Noise would be generated during construction of the pipeline and during construction and 

operation of the proposed LNG terminal. At any location, both the magnitude and frequency of 

environmental noise may vary considerably over the course of the day and throughout the week. This 

variation is caused in part by changing weather conditions and the effects of seasonal vegetative cover. 

Federal agencies use two measures to relate the time-varying quality of environmental noise to its known 

effect on people. 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. A second measure, the day-night 

equivalent sound level (Ldn) is calculated by adding 10 decibels on the A-weighted scale (dBA) to the 

nighttime sound levels between the hours of 10 p.m. and 7 a.m. to account for the greater sensitivity of 

people to sound during the nighttime hours. The A-weighted scale is used because human hearing is less 

sensitive to low and high frequencies than mid-range frequencies. 

4.11.2.1 Noise Regulations 

In 1974, the EPA published Information on Levels of Environmental Noise Requisite to Protect 

Public Health and Welfare with an Adequate Margin of Safety (EPA, 1974). 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 in order to protect the public from activity interference and annoyance outdoors in 

residential areas, noise levels should not exceed an Ldn of 55 dBA. 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. The FERC has 

adopted this criterion for new compression and associated facilities, and it is used here to assess the 

potential noise impact from operation of the LNG terminal. 

There are no additional Mississippi or Jackson County noise ordinances. 

4.11.2.2 Existing Noise Levels 

The acoustical engineering company Hoover & Keith, Inc. (H&K), completed a site survey on 

April 13 and14, 2005 and determined that no Noise Sensitive Areas (NSAs) are located within 1 mile of 

the site. The nearest NSAs are shown on Figure 4.11.2-1 and listed in Table 4.11.2-1. 

TABLE 4.11.2-1 

Nearest Noise Sensitive Areas 

Description Distance To Property Line Direction 

NSA#1 Apartments 1.52 miles W-NW 

NSA#2 Residences 1.46 miles Northwest 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Page 4-107 

Figure 4.11.2-1 Proposed Casotte Landing Project 

Nearest Noise Sensitive Areas 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
4-108 

H&K conducted a baseline noise survey on April 13 and 14, 2005 to record existing ambient 

noise levels at two locations near the NSAs. The measured daytime (Ld) and nighttime (Ln) sound 

pressure levels were then used to calculate the Ldn levels. In addition to noise level measurements, 

contributing noise sources were recorded, along with the prevailing meteorological conditions. Existing 

noise sources during the day consisted of a combination of industrial operations, distant highway traffic, 

birds, insects, and wind. Nighttime noise sources were similar and included barking dogs. 

Meteorological conditions during the monitoring period included sunny/clear skies with temperatures 

ranging from 63 to 80 °F. Wind was from the north. No precipitation was recorded during the survey. 

 The measured Ld and Ln ambient levels and the calculated Ldn levels are summarized in 

Table 4.11.2-2. 

TABLE 4.11.2-2 

Background Noise Levels at Nearest Noise Sensitive Areas 

Monitoring Location, Date Ld

(dBA) 

Ln

(dBA) 

Ldn 

(dBA) 

NSA#1, April 13, 2005 50.1 46.7 

NSA#1, April 13, 2005 48.7 46.8 

NSA#1, April 13, 2005 49.4 47.3 

NSA#1, April 14, 2005 50.7 

NSA#1, April 14, 2005 50.7 

NSA#1, April 14, 2005 48.9 

NSA#1 Averages 49.7 46.9 53.8 

 

NSA#2, April 13, 2005 47.3 46.8 

NSA#2, April 13, 2005 47.1 47.1 

NSA#2, April 13, 2005 48.1 48.9 

NSA#2, April 14, 2005 49.3 

NSA#2, April 14, 2005 51.3 

NSA#2, April 14, 2005 50.8 

NSA#2 Averages 49.0 47.5 54.2 

The existing Ld and Ln noise levels at NSA#1 ranged from 48.9 to 50.7 dBA during the day and 

from 46.7 to 47.3 dBA at night. The calculated Ldn value was 53.8 dBA at NSA#1. The existing Ld and Ln

noise levels at NSA#2 ranged from 47.1 to 51.3 dBA during the day and from 46.8 to 48.9 dBA at night. 

The calculated Ldn value was 54.2 dBA at NSA#2. 

4.11.2.3 Impact and Mitigation 

Potential impacts from the proposed Project would be caused by temporary increases in noise 

during construction and permanent increases in noise due to operation of the Project. These potential 

noise increases were compared with the FERC standard for permissible noise at NSAs. 

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Construction Noise 

Construction activities at the proposed LNG terminal would generate temporary increases in 

noise over an approximate three-year period. Increases in noise would vary depending on the type of 

construction activity in progress. The initial phase of construction, which involves excavation, filling, 

grading, and pile driving with heavy earth-moving equipment, would generate relatively high noise levels. 

Significant noise levels would also result from dredging of the marine terminal and from pile driving 

associated with construction of marine facilities. 

Heavy equipment would be the primary noise source during the excavation and construction 

phase. Noise levels from construction equipment would typically range from 75 to 98 dBA at 50 feet 

from the source. Estimated noise levels from typical construction equipment are listed in Table 4.11.2-3. 

After accounting for attenuation due to air absorption and due to the distance to the nearest noise sensitive 

area, construction activity noise at NSA#1 is calculated to be 47.4 dBA Ldn. The expected construction 

noise level is below existing ambient noise levels at the NSAs. 

TABLE 4.11.2-3 

Estimated Construction Equipment Noise 

Equipment Type Noise at 50 feet (dBA) 

Forklift 75 

Diesel Generator 81 

Welders 78 

Bulldozer, Grader, Front End Loader 85 

Trucks 88 

Backhoe 80 

Pile Driving 98 

____________ 

Source: H&K, May 2005 

Dredging activities would occur 24 hours per day, seven days per week. Primary noise sources 

would include diesel dredges with associated pumps. Noise levels associated with the dredging activities 

would be 90 dBA at a distance of 50 feet. The predicted noise level at NSA#1, 5500 feet from the 

dredging site, was calculated to be 42.4 dBA Ldn after accounting for attenuation due to air absorption and 

due to the distance from the noise source to NSA#1. The expected dredging noise level is below existing 

ambient noise levels at the NSAs. 

Pile driving would be required intermittently for a period of about 36 months during construction 

of the unloading platforms, trestles, and mooring/breasting dolphins. Noise from pile driving activities 

would depend on the type of pile and equipment used. Noise generated by pile driving was estimated at 

101 dBA at a distance of 50 feet. The predicted noise level at NSA#1, 5500 feet from the pile driving site, 

was calculated to be 50.4 dBA Ldn after accounting for attenuation due to air absorption and due to the 

distance from the noise source to NSA#1. The expected dredging noise level is below existing ambient 

noise levels at the NSAs. 

The predicted noise levels at the nearest NSA during excavation, dredging, and pile driving, 

would be below the FERC’s Ldn of 55 dBA. Although construction activities at the LNG terminal may be 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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audible during relatively quiet periods, noise-related impacts are expected to be minimal and no 

mitigation would be required. 

Operational Noise 

H&K calculated predicted noise levels that would be generated by operation of the proposed 

LNG terminal. H&K based its calculations on field noise measurements of similar existing types of 

equipment as shown in Table 4.11.2-4. Sound levels range from 97 to 120 dBA. 

TABLE 4.11.2-4 

Equipment Quantities and Sound Power Levels Used in Noise Modeling 

Equipment Assumed Number in Use Sound Power Level per Item (dBA) 

Boil-Off Gas Compressor 2 120 

Vapor Return Blowers 2 114 

LNG Pumps 3 99 

LNG Sendout Pumps 6 103 

Instrument Air Compressors 3 101 

Electrical Substation 1 96 

Aboveground Piping NA 115 

NGL Feed Pumps 3 100 

Demethanizer Feed Pumps 3 99 

Deethanizer Reflux Pumps 2 97 

Ethane Product Pumps 3 99 

Propylene Glycol Pumps 3 103 

Demethanizer Y Grade Pumps 2 100 

Deethanizer Y Grade Pumps 2 100 

Miscellaneous Equipment NA 100 

____________ 

NA – Not Applicable 

After accounting for attenuation due to air absorption and due to the distance to the nearest noise 

sensitive area, the predicted noise contribution of terminal operation at NSA#1 is 38.7 dBA. 

Table 4.11.2-5 presents the results of the calculated noise level after adding the facility noise to 

the existing ambient noise levels at the nearest NSA. 

TABLE 4.11.2-5 

Predicted Ldn Noise Levels at Nearest NSA 

NSA 

Distance and 

Direction 

Existing 

Ambient Ldn

(dBA) 

Predicted Facility 

Contribution 

(dBA) 

Ambient + 

Facility 

(dBA) 

Predicted 

Increase in 

Ambient 

(dBA) 

NSA# 2 1.46 Miles NW 54.2 38.7 dBA 54.2 0.0 

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The predicted facility contributions of 38.7 dBA at NSA #1 is below the existing ambient noise 

level and would not increase the Ldn noise level at the nearest NSA. Although noise from the proposed 

LNG terminal may be perceptible during relatively quiet periods, the facility would not contribute to 

typical existing background noise conditions. As such, we anticipate that the proposed LNG terminal 

would be in compliance with our noise standard. We recognize, however, that actual results may be 

different from the calculated estimates. Therefore, we recommend that: 

• Bayou Casotte Energy make all reasonable efforts to ensure its predicted noise levels 

from the LNG terminal are not exceeded at the NSA and file noise surveys with the 

Secretary no later than 60 days after placing the LNG terminal in service. However, if 

the noise attributable to the operation of the LNG terminal exceeds 55 dBA Ldn at a 

NSA, Bayou Casotte Energy should file a report on what changes are needed and should 

install additional noise controls to meet the level within 1 year of the in-service date. 

Bayou Casotte Energy should confirm compliance with these requirements by filing a 

second noise survey with the secretary no later than 60 days after it installs the 

additional noise controls. 

Vessel traffic associated with operation of the project would generate underwater sounds. Cargo 

vessels, which are in the same category as LNG ships, are known to emit high levels of low frequency 

sound (6.8 to 7.7 hertz at 181 to 190 decibels (re: 1 μPa)) capable of traveling long distances (Richardson 

et al., 1995). Noise generated by LNG marine traffic is generally omni-directional, emitting from all 

sides of the vessel (Whale and Dolphin Conservation Society 2004). However, noise levels are greatest 

on the sides of the ship and weakest on the front and rear of the ship. As discussed in section 4.5.2.2, fish 

may exhibit a transient avoidance behavior in response to LNG ship noise along the waterway from the 

territorial seas to the proposed LNG terminal. Above-water noise associated with the LNG marine traffic 

would occur in areas with no sensitive noise receptors or in areas where similar other large vessel traffic 

occurs and would not result in significant impacts on environmental resources. 

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 the safety of 

LNG carriers and the marine transfer area. The Coast Guard also has authority for LNG facility security 

plan review, approval, and compliance verification as provided in Tile 33 CFR Part 105, and siting as it 

pertains to the management of vessel traffic in and around the 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(s). 

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 tanker operations, and to maximize 

the exchange of information related to the safety and security aspects of the LNG facilities and related 

marine operations. The Interagency Agreement ensures a seamless safety and security review by the 

three federal agencies. 

The operation of the proposed Casotte Landing LNG Project 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 offDocument Accession #: 20061222-4000 Filed Date: 12/22/2006
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site 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. 

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.2

 

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 liquid petroleum 

gas (LPG) 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 of the proposal by Bayou Casotte Energy (i.e., high-pressure steam boilers that power refrigerant 

compressors would not be used here nor are they used at any LNG facility under the FERC jurisdiction), 

the sequence of cascading events identifies potential failure modes that warrant further evaluation. To 

ensure that all potential hazards are addressed, 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. Storage and retention systems are discussed in Section 

4.12.3. An analysis of the thermal radiation and flammable vapor cloud hazards resulting from a credible 

land-based LNG spill is presented in Section 4.12.4, while the safety aspects of LNG transportation by 

ship is discussed and summarized in Section 4.12.5. A discussion on security awareness related to 

terrorism is presented in Section 4.12.6. A discussion of pipeline safety is presented in Section 4.12.7. 

Conclusions on safety issues are in Section 4.12.8. 

 

2

 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.” 

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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, 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. 

Methane, the primary component of LNG, is colorless, odorless and tasteless, and is classified as 

a simple asphyxiant. Methane could, however, cause extreme health hazards, including death, if inhaled 

in significant quantities within a limited time. At very cold temperatures, methane vapors could cause 

freeze burns. Asphyxiation, like freezing, normally represents a negligible risk to the public from LNG 

facilities. 

When released from its containment vessel and/or transfer system, LNG will first produce a vapor 

or gas. This vapor, if ignited, represents the primary hazard to the public. LNG vaporizes rapidly when 

exposed to ambient heat sources such as water or soil, producing 620 to 630 standard cubic feet of natural 

gas for each cubic foot of liquid. LNG vapors in a 5 to 15 percent mixture with air are highly flammable. 

The amount of flammable vapor produced per unit of time depends on factors such as wind conditions, 

the amount of LNG spilled, and whether it is spilled on water or land. Depending on the amount spilled, 

LNG may form a liquid pool that will spread unless contained by a dike. 

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. An unconfined methane-air mixture will burn slowly, tending to ignite combustible 

materials within the vapor cloud, whereas fast flame speeds tend to produce flash burns rather than selfsustaining ignition. 

LNG is not explosive as it is normally transported and stored. However, LNG vapors (primarily 

methane) can explode if contained within a confined space, such as a building or structure, or confined 

space aboard an LNG ship, and ignited. There is no evidence, however, suggesting that LNG is explosive 

in unconfined open areas. Experiments to determine if unconfined methane-air mixtures will explode 

have been conducted and, to date, have all been negative. Unconfined methane-air mixtures will burn but 

will not explode. Nevertheless, a number of experimental programs have been conducted to determine 

the “amount of initiator charge” required to detonate an unconfined methane-air mixture. 

Over the years, various parties have occasionally expressed the energy content of an LNG storage 

tank or LNG carrier in equivalent tons of trinitrotoluene (TNT), as an implied measure of its 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 an explosion 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 of about 20-25 meters/second (66-82 feet/second) and local over pressures up 

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to 0.2 psig have been estimated for methane-rich fuels, well below the flame speeds and over pressures 

associated with explosion. 

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 as described above, 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 

overpressures generated 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 TNT. Such a small overpressure is not expected to cause significant 

damage to an LNG carrier. However, the RPT may increase the rate of LNG pool spreading and the LNG 

vaporization rate. 

4.12.2 Cryogenic Design and Technical Review 

The cryogenic 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 Bayou Casotte 

Energy LNG terminal has been performed by the FERC staff. The design and specifications submitted 

for the proposed facility 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 submitted to the FERC staff for review and approval. 

As a result of the technical review of the information provided by Bayou Casotte Energy in the 

submittal documents, a number of concerns were identified by staff relating to the reliability, operability, 

and safety of the proposed design. In response to staff’s questions, Bayou Casotte Energy provided 

written answers prior to the technical conference on April 5, 2006. 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 should apply to the LNG terminal design and construction 

details. Information pertaining to these specific recommendations should be filed with 

the Secretary 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 recommendation. Items relating 

to Resource Report 13-Engineering and Design Material and security should be 

submitted as critical energy infrastructure information (CEII) pursuant to 18 CFR § 

388.112 and PL01-1. 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. Bayou Casotte 

Energy should file this information a minimum of 30 days before approval to proceed is 

required. 

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• Complete plan drawings and a list of the hazard detection equipment should be filed 

prior to initial site preparation. The list should include a list with the instrument tag 

number, 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. 

• A technical review addressing the following information for the proposed facility should 

be filed prior to initial site preparation: 

a. Identification of all combustion/ventilation air intake equipment and the 

distances to any possible hydrocarbon release (LNG, flammable refrigerants, 

flammable liquids and flammable gases); and 

b. A demonstration that these areas are adequately covered by hazard detection 

devices, including a description of how these devices would isolate or shutdown 

any combustion equipment whose continued operation could add to or sustain 

an emergency. 

• Complete plan drawings and a list of the fixed and wheeled dry-chemical, fire 

extinguishing, and high expansion foam hazard control equipment should be filed prior 

to initial site preparation. The list should include a list with 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.

• Drawings of the storage tank piping support structure and support of horizontal piping 

at grade should be filed prior to initial site preparation.

• The P&IDs and design information for the NGL Recovery System should be submitted 

prior to initial site preparation.

• Procedures should be developed for offsite contractors’ responsibilities, restrictions, 

limitations and supervision of these contractors by Bayou Casotte Energy staff, prior to 

initial site preparation.

• The final design of the hazard detection equipment should identify manufacturer and 

model. 

• The final design of the fixed and wheeled dry-chemical, fire extinguishing, and high 

expansion foam hazard control equipment should identify manufacturer and model. 

• The final design should include detailed drawings of the spill control system to be 

applied to the LNG tank roof. 

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• The final design should specify that the LNG tank carbon steel piping support plates 

and connections to piping supports should be designed to ensure that corrosion 

protection is adequately provided and provisions for corrosion monitoring and 

maintenance of carbon steel attachments are to be included in the design and 

maintenance procedures. 

• The final design should include details of the LNG tank tilt settlement and differential 

settlement limits between each LNG tank and piping and procedures to be implemented 

in the event that limits are exceeded. 

• The final design should include details of the pipe supports and restraints designed to 

prevent damage to piping systems and equipment in the event of a storm surge 

anticipated for a class 4 hurricane. 

• The final design should include provisions to install LNG transfer pumps at Jetty KO 

drum. 

• The final design should include details of the boiloff gas flow and temperature 

measurement for each tank. 

• The final design should include bypass valves around the intank discharge valves for 

cooldown of the 24-inch headers and piping. 

• The final design should include an automatic shutoff valve in the LNG intermediate 

pump inlet line from the suction header. 

• The final design should include an automatic shutoff valve in the LNG sendout pump 

inlet line from the suction header. 

• The final design should include P&IDs and drawings of the meter station. 

• The final design should include a fire protection evaluation carried out in accordance 

with the requirements of NFPA 59A, chapter 9.1.2. 

• 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 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 (HAZOP) review of the 

completed design. A copy of the review and a list of the recommendations should be 

filed. 

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• The P&IDs in the final design should show and number all valves including drain, vent, 

main, and car sealed. 

• The final design should include safeguards to be installed to protect above ground fire 

water piping, including post indicator valves, from inadvertent damage. 

• The final design should specify that all hazard detection equipment should include 

redundancy and fault detection and fault alarm monitoring in all potentially hazardous 

areas and enclosures. 

• All valves including drain, vent, main, and car sealed valves should be tagged in the 

field during construction and prior to commissioning. Instrumentation valves are 

excluded from this recommendation. 

• 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 list 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 contingency plan for failure of the LNG tank outer containment, approved by the 

tank manufacturer should be filed prior to commissioning. 

• A copy of the criteria for horizontal and rotational movement of the inner tank for use 

during and after cool down should be filed prior to commissioning. 

• The maintenance procedures to be filed prior to commissioning should state that a 

foundation elevation survey of all LNG tanks should be made on an annual basis. 

• 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. 

• Progress on the construction of the LNG terminal should be reported in monthly

reports filed with the Secretary. 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, the Company 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. 

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Up-to-date detailed piping and instrumentation diagrams reflecting facility 

modifications and provision of other pertinent information not included in the semiannual reports described below, including facility events that have taken place since the 

previously submitted 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 ship 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, including 

imbedded pipe supports, 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 enter site, suspicious 

activities) should 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 should be made immediately, without unduly 

interfering with any necessary or appropriate emergency repair, alarm, or other 

emergency procedure. In all instances, notification should 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 

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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. 

Recent hurricane activity in the Gulf Coast region has increased concerns about the possible 

effects of natural disasters on existing and proposed LNG facilities. The 2005 Atlantic hurricane season 

was the most active season on record with hurricanes Katrina and Rita directly affecting Gulf Coast port 

areas in which existing, under-construction, and planned terminals are located. The FERC staff, 

recognizing the recent trend in the region towards more numerous and powerful storms, has intensified its 

review of the design criteria for the Casotte Landing LNG facility with respect to high wind speed and 

storm surge conditions. 

Storm surge refers to water levels above normal tide levels caused by wind and pressure effects 

associated with hurricanes. Bayou Casotte Energy proposes to construct a hurricane protection levee to 

an elevation of 24 feet which exceeds the 100 year return storm criteria. The LNG unloading platform 

deck elevation was set at 29 feet. The Terminal’s specified design criteria include sustaining wind of 150 

mile per hour and 3-second wind gusts of 183 miles per hour at 33 feet above ground. The Staff agrees 

that the design is adequate for predicted storm surge and wave height levels. 

4.12.3 Storage and Retention Systems 

LNG storage tanks come in a variety of categories. The following are descriptions of the tank 

designs most commonly used worldwide: 

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• single containment cylindrical metal tanks (predominately used in the U.S.); 

• spherical storage tanks (predominately used in LNG carriers); 

• double containment cylindrical metal inner tank and metal or concrete outer tank (commonly 

thought of as an LNG tank with a high wall dike); 

• full containment cylindrical metal inner tank and metal or concrete outer tank (the design 

proposed by Bayou Casotte Energy is of this type); 

• pre-stressed cylindrical concrete tank with an internal metal membrane (membrane tank). 

(None in the U.S.); and 

• cryogenic cylindrical concrete tank, internal cryogenic tank, and pre-stressed concrete outer 

tank (one operational in the U.S.; the remainder worldwide). 

These tank categories are described in Annex H of the European Standard for LNG facilities 

(EN 1473) and are summarized below for the LNG storage tanks commonly found in proposals before the 

Commission. 

H.1 Single containment tank 

A single primary container and generally an outer shell designed and constructed so 

that only the primary container is required to meet the low temperature ductility requirements 

for storage of the product. 

The outer shell (if any) of a single containment storage tank is primarily for the 

retention and protection of insulation and to contain the purge gas pressure, but is not 

designed to contain refrigerated liquid in the event of leakage from the primary container. 

An aboveground single containment tank shall be surrounded by a (bund) dike wall 

to contain any leakage. Examples of single containment are given in Figure H.1. 

H.3 Double containment tank 

A double containment tank is designed and constructed so that both the inner selfsupporting primary container and the secondary container are capable of independently 

containing the refrigerated liquid stored. To minimize the pool of escaping liquid, the 

secondary container should be located at a distance not exceeding 6 meters from the primary 

container. 

The primary container contains the refrigerated liquid under normal operating 

conditions. The secondary container is intended to contain any leakage of the refrigerated 

liquid, but it is not intended to contain any vapor resulting from this leakage. 

Examples of double containment tanks are given in Figure H.3. Figure H.3 does not 

imply that the secondary container is necessarily as high as the primary container. 

H.4 Full containment tank 

A tank designed and constructed so that both self supporting primary container and 

the secondary container are capable of independently containing the refrigerated liquid stored 

and for one of them its vapor. The secondary container can be 3 to 6 feet (1 or 2 meters) in 

distance from the primary container. 

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The primary container contains the refrigerated liquid under normal operating 

conditions. The outer roof is supported by the secondary container. The secondary container 

shall be capable both of containing the refrigerated liquid and of controlled venting of the 

vapor resulting from product leakage after a credible event. Examples of full containment 

tanks are given in Figure H.4. 

Single-, double- and full-containment LNG storage tanks have been authorized by the FERC for 

use at new LNG import facilities or expansions of existing terminals. To date, only single- and doublecontainment tanks have been constructed and operated. Several full-containment tanks have started 

construction in the United States, while approximately 50 have been constructed worldwide. During the 

review of earlier proposals, a number of issues surfaced concerning the applicability of existing codes and 

regulations to full-containment tanks. Specifically, the term “full containment” does not appear in U.S. 

codes or standards for LNG facilities, including the Federal Safety Standards in Title 49 CFR Part 193, 

NFPA 59A, or American Petroleum Institute 620. As a result, some project proponents have made the 

assumption that to design and construct a full-containment tank in accordance with EN 1473 will satisfy 

the U.S. codes and standards. 

For example, it has been suggested that thermal exclusion zones are not required for a fullcontainment tank because EN 1473 does not consider a tank fire scenario for full-containment tanks with 

a pre-stressed concrete wall and concrete roof. The staffs of the FERC and the Office of Pipeline Safety 

(OPS) do not agree because neither NFPA 59A nor Part 193 excludes full-containment tanks from 

thermal exclusion zone requirements. As a result, a thermal exclusion zone analysis is required for an 

LNG storage tank fire at the top of the secondary container (see Section 4.13.4). 

Further, EN 1473 does not specify a minimum distance to the property line for full-containment 

tanks because no tank fire scenario is considered. However, NFPA 59A requires a separation of 0.7 times 

the tank diameter from the property line. Bayou Casotte Energy’s proposed tank separation distance to 

the property line meets this separation requirement. 

Another issue regarding the full-containment design is that the tank outer wall (secondary 

containment) serves as the impoundment, a concept allowed under Parts 193.2161 and 193.2167, and 

under the “exception” in Figure 2.2.2.6 of NFPA 59A. A specific concern is the dual function of the 

concrete secondary container - it serves both the operational function of holding the insulation and gas 

pressure, and a safety function of containing liquid in the event of an inner tank failure. Conversely, in 

single- and double-containment tanks, independent systems provide operational and safety functions. 

While recognition must be given to the benefits of a concrete secondary container with respect to external 

events, such as projectiles or small aircraft, its ability to provide the dual functions while retaining its 

integrity has not been convincingly supported for all scenarios. This becomes increasingly important as 

proposed site acreage is reduced and buffer zones between adjacent properties are minimized. As such, 

the FERC staff considers it prudent design practice to provide some form of barrier to prevent liquid from 

flowing to an unintended area (i.e., outside the plant property) in the event that the storage tank primary 

and secondary containers fail. 

Concerns have also been expressed that the barrier could be considered a containment and 

prohibit certain equipment being located within the barrier and/or may conflict with other parts of the 

various codes with respect to hazardous and electrical code classifications. Other concerns are that the 

barrier could be considered an impounding area that would require new thermal and vapor cloud 

calculations. The purpose of the barrier is to prevent liquid from flowing off the plant property, and it is 

not the intent to define a containment or impounding area for thermal radiation or flammable vapor 

exclusion zone calculations or other code requirements. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Figure H-1 

Examples of Single Containment Tanks 

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Figure H-3 

Examples of Double Containment Tanks 

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Figure H-4 

Examples of Full Containment Tanks 

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4-125

Bayou Casotte Energy proposes to install a hurricane protection levee around the LNG storage 

tanks. The structure would have a height of 24 feet and would enclose an area approximately 1,161 feet 

by 1,731 feet. The structure's volumetric capacity would exceed 100 percent of a single LNG tank's 

maximum liquid capacity. Rainwater that collects inside the hurricane protection levee would be drained 

into the spill impoundment basin and pumped out in accordance with 49 CFR 193.2173. This hurricane 

protection levee would confine LNG on the project site in the event of any hypothetical catastrophic 

event. 

4.12.4 Siting Requirements – Thermal and Vapor Dispersion Exclusion Zones 

4.12.4.1 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 NFPA 59A (1996 

edition) 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 off-site hazards: 

• 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. 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. 

• 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. 

For the following LNG facilities that are proposed in this project, we have identified the 

applicable siting requirements from Part 193 and NFPA 59A: 

• Three 1,006,000-barrel (160,000 m3

) full containment LNG storage tanks - Parts 193.2057 

and 2059 require the establishment of thermal and flammable vapor exclusion zones for LNG 

tanks. NFPA 59A Section 2.2.3.2 specifies four thermal exclusion zones based on the design 

spill and the impounding area. NFPA 59A Sections 2.2.3.3 and 2.2.3.4 specify a flammable 

vapor exclusion zone for the design spill, which is determined with Section 2.2.3.5. 

• A slip with one LNG berth and a marine cargo transfer system consisting of three 16-inchdiameter liquid transfer arms; one 16-inch-diameter vapor return arm; three 20-inch 

connecting pipes; and two underground 32-inch-diameter transfer lines - Parts 193.2001, 

2057, and 2059 require thermal and flammable vapor exclusion zones for the transfer system. 

NFPA 59A does not address LNG transfer systems. 

• Nine 4,211 gallons per minute (gpm) in-tank pumps (three per tank) with a common 

warehouse spare pump; four 3,810 gpm intermediate pressure pumps; and six 2,730 gpm 

high-pressure sendout pumps - Parts 193.2057 and 2059 require thermal and flammable vapor 

exclusion zones. NFPA 59A Section 2.2.3.2 specifies the thermal exclusion zone and 

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Sections 2.2.3.3 and 2.2.3.4 specify the flammable vapor exclusion zone based on the design 

spill. 

• Six intermediate fluid 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 ship 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 (2001) 

specifically excludes transfer area at the water edge of marine terminals. When the DOT 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 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 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 Office of Pipeline Safety [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 for exclusion zone calculations. 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 discussions with DOT OPS concerning the basis for 

design spills and application to exclusion zone determinations for proposals before the Commission. 

4.12.4.2 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. Bayou Casotte 

Energy proposed a full containment storage tank design, which consists of a primary inner container and a 

secondary outer container. Each LNG storage tank’s maximum liquid capacity would be 45,674,277 

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gallons. The volumetric capacity of the concrete wall would be 52,228,786 gallons, which would exceed 

the 110 percent requirement by 1,987,081 gallons. 

Bayou Casotte Energy proposes to install two insulated concrete impoundment basins, the Jetty 

Impoundment Basin and the Impoundment Basin, at the LNG terminal site. The Jetty Impoundment 

Basin would be located approximately 500-feet east of the marine unloading berth and would measure 

60-feet wide by 60-feet wide with a depth of 30-feet, a usable capacity of 807,896 gallons. The 

maximum flow in the docking area would be from the guillotine rupture of the 20-inch-diameter 

unloading line that connects to the unloading arm, a 30,800 gpm flow rate equating to a 10-minute spill 

volume of 308,000 gallons. The 20-inch-diameter unloading lines would feed two underground 32-

inch-diameter vacuum-jacketed LNG transfer lines to the LNG storage tanks. The Impoundment Basin 

would be located south of the LNG storage tanks, within the hurricane protection levee, and be sized for a 

full rupture of the above ground section of the 32-inch-diameter LNG transfer line, a 10-minutes spill 

volume of 793,000 gallons. The Impoundment Basin would measure 60-feet-wide by 60-feet-wide with a 

depth of 30-feet, a usable capacity of 807,896 gallons. Bayou Casotte Energy sized both impoundment 

basins with volumes larger than the current proposal for LNG transfer capacities due to the anticipation of 

adding another 16-inch unloading arm in the future. 

The Impoundment Basin would also contain spills from the in-tank pump withdrawal header and 

the LNG process area. Each LNG storage tank would be equipped with three in-tank pumps, each rated at 

4,211 gpm. With three pumps operating, the volume for a 10-minute spill from the in-tank pump 

withdrawal header would be 12,633 gpm, which equates to a 10-minute spill volume of 126,330 gallons. 

The maximum flow from the LNG process area would be from the high pressure pump suction header. A 

10-minute spill from the high pressure pump suction header would release 133,670 gallons of LNG. 

In accordance with Section 2.2.3.5 of NFPA 59A, the design spill for an LNG storage tank with 

no penetrations below the liquid level is defined as the largest flow from any single line that could be 

pumped into the impounding area with the tank withdrawal pumps considered to be operating at full rated 

capacity over a 10-minute period. A rupture of the in-tank pump withdrawal header would result in a 

spill rate of 12,633 gpm, a 10-minute spill volume of 126,330 gallons. Section 2.2.3.5 of NFPA 59A also 

states that the design spill for the impounding areas serving only vaporization, process, or LNG transfer 

areas is the flow from any single accidental leakage source for a 10-minute duration. Staff considered 

that credible LNG spill for the LNG process area could result from breaks from a broken 6-inch recycle 

line downstream of each single high pressure pump. This spill would generate a 10-minute spill volume 

of 27,300 gallons. Each of these individual spills would be contained by the Impoundment Basin. 

Design spill from the unloading dock would be contained by the Jetty Impoundment Basin. Staff 

considered the design spill at the unloading dock could result from an accidental release of the 2-inch 

drain line. The design spill size for this accidental release would be 14,990 gallons. 

Table 4.12.4-1 presents the impounding areas and spill size volumes used to determine adequate 

impounding capacity and the associated design spills. The largest design spill collected by a given sump 

would be used to calculate exclusion zones for that sump. 

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TABLE 4.12.4-1 

Impoundment Areas 

Source 

Spill Size 

(gallons) Impoundment System 

Impoundment Size 

(gallons) 

Impoundment sizing spills: 

LNG Storage Tank 50,241,705 Concrete Wall 52,228,786 

In-tank pump withdrawal header 126,330 Impoundment Basin 807,896 

High pressure pumps suction header 133,670 Impoundment Basin 807,896 

20-inch loading arm line 308,000 Jetty Impoundment Basin 807,896 

Design spills: 

In-tank pump withdrawal header 126,330 Impoundment Basin 807,896 

High pressure pump – 6-inch connection 27,300 Impoundment Basin 807,896 

Unloading dock – 2-inch connection 14,991 Jetty Impoundment Basin 807,896 

4.12.4.3 Thermal Exclusion Zone 

If a large quantity of LNG is spilled in the presence of an ignition source, the resulting LNG pool 

fire could cause high levels of thermal radiation. Exclusion distances for various flux levels were 

calculated according to 49 CFR 193.2057 and Section 2.2.3.2 of NFPA 59A, using the "LNGFIRE III" 

computer program model developed by the Gas Research Institute. NFPA 59A establishes certain 

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 supersedes these requirements and stipulates that 

wind speed, ambient temperature, and relative humidity which produce the maximum exclusion distances 

must be used, except for conditions that occur less than five percent of the time based on recorded data for 

the area. For its analysis, Bayou Casotte Energy selected highly conservative ambient conditions that 

occur less than 5 percent to produce the maximum distances: wind speed of 25 mph; ambient temperature 

of 32°F; and 30 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. We agree 

with Bayou Casotte Energy’s selection of atmospheric conditions. 

Thermal radiation distances were calculated for 1,600 to 10,000 British thermal units per square 

foot per hour (Btu/ft2-hr) incident flux levels for an LNG storage tank impoundment fire. The model was 

run for a full containment tank with roof failure and fire at a diameter of 264 feet and a height of 155 feet. 

Target height was set at ground level (0 feet). In addition, the thermal radiation distances were 

determined for the 1,600-Btu/ft2-hr incident flux level centered on both the Impoundment Basin and the 

Jetty Impoundment Basin. 

Table 4.12.4-2 presents the calculated maximum distances for incident flux levels ranging from 

1,600 to 10,000-Btu/ft2-hr, as verified by the FERC staff. Since all thermal exclusion zones remain 

completely on the proposed plant site, Bayou Casotte Energy’s proposed terminal would satisfy the 

thermal exclusion zone requirements of 49 CFR 193.2057. 

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TABLE 4.12.4-2 

Thermal Exclusion Zones 

Source 

Exclusion Area NFPA 59A 

Section 2-2.3.2(a) 

Incident Flux 

(Btu/ft2 hr) 

(a/) 

Exclusion 

Zone (feet) 

Jetty Impoundment Basin Property line that can be built upon. 1,600 325 

Impoundment Basin Property line that can be built upon. 1,600 325 

LNG Storage Tank 

Impoundment 

Outdoor assembly area occupied by 50 or more 

people. 1,600 962 

LNG Storage Tank 

Impoundment 

Off-site structures used for occupancies or 

residences. 3,000 759 

LNG Storage Tank 

Impoundment Property line that can be built upon. 10,000 416 

_____________ 

NOTE: 

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. 

4.12.4.4 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 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 (one half 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. For its vapor dispersion analysis, 

Bayou Casotte Energy selected the following ambient conditions: stability Class F, 4.5 mph wind speed, 

50 percent relative humidity, and an average regional temperature of 70 °F. 

In accordance with Section 2.2.3.3 of NFPA 59A, an average concentration of methane in air of 

50 percent of the LFL cannot cross the property line from a design spill into each tank impoundment. In 

this case, compliance with Section 2.2.3.3 would also meet the requirements of Section 2.2.3.4 of NFPA 

59A. According to Table 2.2.3.5 of NFPA 59A, the design spill is the largest flow from the container 

(i.e., storage tank) withdrawal pumps for a 10-minute duration at full-rated capacity. This would be a 

guillotine rupture of the discharge header for the in-tank LNG pumps. 

Based on Table 4.12.4-1, the largest design spill that would be directed to the Impoundment 

Basin would come from the LNG tank withdrawal header, a 10-minute spill volume of 126,330 gallons. 

Using this spill and the specifications provided by Bayou Casotte Energy for the Impoundment Basin, 

staff calculated a distance of 340 feet to the 2.5 percent average gas concentration isopleth. Based on this 

distance, the vapor exclusion zone associated with the Impoundment Basin would remain on-site. For the 

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Jetty Impoundment Basin, the FERC staff performed vapor dispersion analyses modeled as continuous 

10-minute spills from a rupture of the 2-inch drain line at the unloading dock, a 10-minute spill volume of 

14,991 gallons. In calculating vapor dispersion from the Jetty Impoundment Basin, SOURCE5 and 

DEGADIS predict 155 feet to the edge of the 1⁄2 LFL concentration envelope. This exclusion zone would 

not extend beyond the terminal property line. Since the vapor exclusion zones from the Impoundment 

Basin and the Jetty Impoundment Basin remain on site, Bayou Casotte’s proposed terminal would satisfy 

the vapor exclusion zone requirements of 49 CFR 193.2057. 

4.12.5 Marine Safety3

 

The February 2004 Interagency Agreement provides the framework for the participating agencies 

to work in a coordinated manner to address the full range of issues regarding safety and security at LNG 

import terminals and the suitability of waterways for LNG marine traffic. The FERC closely coordinates 

its pre-certificate review of the proposal with the Coast Guard, which has authority over the safety of 

LNG carriers and the marine transfer area as well as the security of the LNG carriers and the entire LNG 

facility, and the suitability of waterways for LNG marine traffic. 

The hazards associated with the marine transportation of LNG differ from land-based hazards. 

Whereas the land-based facilities have features to both limit the duration of LNG spills and contain 

credible spill volumes, an LNG spill on water may be unconfined and may vaporize rapidly due to heat 

input from the water. 

The history of LNG shipping has been free of major incidents, and none have resulted in 

significant quantities of cargo being released (see Section 4.12.5.4). 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 ship over the duration of the 

proposed project must be considered. Historically, the events most likely to cause a significant release of 

LNG were ship casualties such as: 

• a vessel colliding with an LNG carrier in transit; 

• an LNG carrier alliding4

 with the terminal or a structure in the waterway; 

• a vessel alliding with an LNG carrier while moored at the terminal; or 

• a grounding sufficiently severe to puncture an LNG cargo tank. 

Since the attacks on September 11, 2001, additional risks are considered due to the possibility of 

a deliberate attack on an LNG ship by a terrorist group. 

Any of the above events would have to occur with sufficient impact to breach the LNG carrier’s 

double hull and cargo tanks. Previous incidents with LNG marine traffic have primarily involved 

grounding, and none of these have resulted in the breach of the double hull and subsequent release of 

LNG cargo. 

 

3 This section was written with the cooperation and assistance of the Coast Guard, Sector Mobile. 

4 “Allision” is the action of dashing against or striking upon a stationary object (e.g., 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. 

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The following discussion provides a chronology of a conceptual LNG carrier voyage, as proposed 

by the applicant, from the liquefaction facility to the import terminal, disclosing the risks at each step and 

how they would be managed. Details and analysis are provided in subsequent sections. 

LNG Carriers and Ocean Voyage 

Imported LNG could be obtained from exporting terminals throughout the world and delivered by 

LNG carriers to the proposed terminal. Exporting countries include Algeria, Australia, Brunei, Indonesia, 

Malaysia, Nigeria, Oman, Qatar, Trinidad, and United Arab Emirates. In 2003, LNG imports to the U.S. 

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. At this time, Bayou Casotte Energy has not 

confirmed the source(s) of LNG supplies. 

The LNG carriers used to import LNG to the U.S. would be constructed and operated in 

accordance with the International Maritime Organization (IMO) Code for the Construction and 

Equipments 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 U.S. safety standards for vessels carrying 

bulk LNG. Foreign flag LNG carriers are required to possess a valid IMO Certificate of Fitness and a 

Coast Guard Certificate of Compliance. 

In 1993, amendments to the IMO’s Code for the Construction and Equipments of Ships Carrying 

Dangerous Chemicals in Bulk require all tankers 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 interbarrier 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 ship; 

• a dry chemical fire extinguishing system for hydrocarbon fires; and 

• a carbon dioxide system for protecting machinery, including the ballast pump room, 

emergency generators, and compressors. 

As a result of September 11, 2001, the IMO agreed to new amendments to the 1974 SOLAS 

addressing port facility and ship security. The International Ship and Port Facility Security Code was 

adopted in 2003 by the IMO. This code requires both ships and ports to conduct vulnerability 

assessments and to develop security plans. The purpose of the code is to: prevent and suppress terrorism 

against ships; improve security aboard ships and ashore; and reduce the risk of passengers, crew, and port 

personnel on board ships and in port areas, for vessels and cargoes. All LNG marine traffic, 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 the ships, these requirements must include: 

• Ships must develop security plans and have a Vessel Security Officer (VSO); 

• Ships must be provided with a ship security alert system. These alarms transmit ship-to-shore 

security alerts to a competent authority designated by the Administration, which may include 

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the company, identifying the ship, its location, and indicating that the security of the ship is 

under threat or has been compromised; 

• Ships must have a comprehensive security plan for international port facilities, focusing on 

areas having direct contact with ships; and 

• Ships may have certain equipment onboard to help maintain or enhance the physical security 

of the ship. 

For the port facilities, the requirements must include: 

• 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. 

Both ships and ports must include the following: 

• Monitoring and controlling access; 

• Monitoring the 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. 

LNG Carrier Transit in Port of Pascagoula 

LNG marine traffic in route to the proposed LNG terminal would transit about the 12.6 nautical 

miles from the Horn Island “HI” sea buoy to the berth under the direction of a Pascagoula Pilot. The 

Pascagoula Pilots are presently the controlling body in terms of scheduling, monitoring of weather 

conditions, establishing working conditions, and declaring channel closure days based on inclement 

weather. Pilots meet ships, day or night, at the sea buoy located at the southern end of the Horn Island 

Pass Channel. 

If the Coast Guard issues a LOR, as described in Section 1.3 “Permits, Approvals, and Regulatory 

Requirements”, finding the waterway suitable for LNG marine traffic with the conditions referenced in 

Section 2.0, LNG marine traffic would access the proposed LNG terminal via the Pascagoula Bar 

Channel starting at the “HI” sea buoy and traveling approximately 3.3 nautical miles to buoys 11 and 12, 

which mark the beginning of the Horn Island Pass Channel. From there, vessels would travel northeast 

for about 1.2 nautical miles, through Horn Island Pass, at which point they would turn north and continue 

along the Lower Pascagoula Channel for about 3.7 nautical miles to the Bayou Casotte Channel, which 

branches off from the Lower Pascagoula Channel at a junction commonly referred to as the “Y.” From 

this junction, LNG marine traffic would continue north approximately 4.4 nautical miles to the LNG 

terminal. Bayou Casotte Energy’s ships would require three tractor tugs with the appropriate bollard pull 

to handle an LNG ship. The berth would be designed such that the LNG vessels could be turned by the 

tugs and backed onto berth or pulled in bow first. 

If the Coast Guard issues a LOR finding the waterway suitable for LNG marine traffic, the LNG 

marine traffic would normally transit arrive and enter the waterway during early daylight hours. Docking, 

LNG offloading, and undocking would take about 24 hours. The LNG marine traffic would depart during 

daylight hours on the second day. 

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If the Coast Guard issues a LOR finding the waterway suitable for LNG marine traffic, in 

addition to the Pascagoula Pilots, the Coast Guard may monitor the transit of the LNG vessel through the 

harbor and while unloading cargo. Typical Coast Guard requirements for other LNG import terminals 

include 96- and 24-hour advance notification of the vessel arrival at the sea buoy, at which time, Coast 

Guard personnel may board the LNG vessel for an inspection of the ship safety systems, a security sweep, 

and review of the manifest. Other Coast Guard requirements may include: establishment of a moving 

safety zone around the vessel while in en route; a Coast Guard escort through the channel and to the dock; 

a fixed security zone around the vessel and during unloading operations; an inspection of the dock safety 

systems prior to commencing cargo transfer; and monitoring of all operations until the vessel departs. 

Maintaining security of the dock and vessel would be the responsibility of the facility in cooperation with 

other federal, state, and local agencies as described in the Facility Security Plan (see Section 4.12.6). 

LNG Carrier Casualties

If the Coast Guard issues a LOR finding the waterway suitable for LNG marine traffic with the 

conditions referenced in Section 2.0, the operational controls that may be imposed by the Coast Guard 

and the Pascagoula Pilots, as well as the characteristics of the Pascagoula Bar, Horn Island Pass, Lower 

Pascagoula, and Bayou Casotte Channels, would minimize the possibility of an LNG cargo spill from 

groundings, collisions, and allisions. The Coast Guard may enforce a moving safety zone around the 

LNG ship that would clear the channel of all vessels in the vicinity of the LNG ship to reduce the 

likelihood of any collisions, including those of the tonnage and speed required to cause an LNG spill (see 

Section 4.12.5.4). 

The Pascagoula Bar Channel is maintained at a width of 450 feet and a depth of 44 feet. The 

Horn Island Pass Channel is 600 feet wide and 44 feet deep. The Lower Pascagoula and Bayou Casotte 

Channels are both maintained at a width of 350 feet and a depth of 42 feet. The channels are bordered by 

shallow water approximately 5 to 18 feet deep, thereby constraining the LNG ships, which have drafts of 

38 feet, to operating within the dredged channels. However, the soft nature of the sea bottom in the 

Mississippi Sound makes an LNG spill from cargo tanks highly unlikely in a grounding incident. 

Deliberate Attack on an LNG Carrier

In addition to addressing the potential hazards from LNG vessel incidents, the possibility of a 

deliberate attack on an LNG ship by a terrorist group must also be considered. Security of the LNG 

vessel is would be the responsibility of the owner/operator and the master of the vessel. Security of the 

LNG facility would be the responsibility of the owner/operator of the facility. If the Coast Guard issues a 

LOR finding the waterway suitable for LNG marine traffic with conditions, the Coast Guard may 

establish a moving safety zone around the LNG marine traffic in transit and a security zone around the 

LNG vessels while docked. Protection of the LNG vessel and the import terminal would involve 

personnel from the Coast Guard, Bayou Casotte Energy security staff, and state and local law 

enforcement. The Coast Guard may also conduct random shoreside and waterside security patrols to 

include visits/passes of the LNG facility. Only personnel or vessels authorized by the Captain of the Port 

(COTP) or the District Commander would be permitted in the safety and security zone. 

Bayou Casotte Energy would provide security for the terminal according to a Facility Security 

Plan that must be prepared under 33 CFR 105. This plan would need to be and approved by the Coast 

Guard COTP (see Section 4.12.6). 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; 

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• 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 three months; and 

• mandatory reporting of all breaches of security and security incidents. 

Security at the facility would be provided by both active and passive systems. The entire site 

would be surrounded by a protective enclosure (i.e., a fence) with sufficient strength to deter unauthorized 

access. The enclosure would also be illuminated with not less than 2.2 lux between sunset and sunrise. 

Intrusion detection systems and day/night camera coverage would identify unauthorized access. A 

separate security staff would conduct 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. 

Bayou Casotte Energy would be required to submit their Facility Security Plan to the COTP for approval 

60 days prior to commencement of operations. In order to ensure that the responsibilities of Bayou 

Casotte Energy’s security staff enhance overall security, we recommend that: 

• Prior to Commissioning, Bayou Casotte Energy coordinate, as needed, with the Coast 

Guard to define the responsibilities of Bayou Casotte Energy’s security staff in 

supplementing other security personnel and in protecting the LNG tankers and the 

terminal. 

The Department of Energy (DOE) 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 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. The analysis of accidental events found that 

groundings and low speed collisions could result in minor ship damage but not a cargo spill; while high 

speed collisions could cause a 0.5 to 1.5 square meters cargo tank breach area. For intentional scenarios, 

the size of the cargo tank hole depends on the location of the ship and source of threat. Intentional breach 

areas were estimated to range from 2 to 12 square meters. In most cases, an intentional breaching 

scenario would not result in a nominal hole of more than 5 to 7 square meters, 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 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. The methodology described in the ABSG study, Consequence 

Assessment Methods for Incidents Involving Releases from Liquefied Natural Gas Carriers, and revised 

in staff’s responses to comments on the report (issued June 18, 2004), was used to calculate the thermal 

radiation and flammable vapor dispersion distances for several holes ranging in diameter from 1 meter to 

3.9 meters. Using the methodology, we have estimated distances for a nominal 2.5-meter and 3-meter 

diameter hole to range from 4,182 to 4,652 feet for a thermal radiation of 1,600 Btu/ft2-hr, the level 

which is hazardous for persons located outdoors and unprotected; from 3,232 to 3,591 feet for 

3,000 Btu/ft2-hr, an acceptable level for wooden structures; and from 1,934 to 2,143 feet for 

10,000 Btu/ft2-hr, a level sufficient to damage process equipment for these size holes, respectively. 

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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. The majority of the transit from the Gulf 

of Mexico through the Pascagoula Bar, Horn Island Pass, Lower Pascagoula, and Bayou Casotte Harbor 

Channels to the LNG berth, has no development or communities adjacent to the channel or within the 

4,652 feet transient hazard area. The last 0.5-mile of the transit would pass by currently undeveloped land 

to the east, but a portion of which is the site of the proposed Gulf LNG Energy LLC terminal 

(Docket No. CP06-12-000). LNG vessels at Gulf LNG Energy LLC’s proposed marine berth would be 

over 600 feet from the channel edge and the LNG storage tanks would be about 2,200 feet from the 

channel edge. Assuming an LNG vessel would transit through the channel between 3 and 10 knots, areas 

adjacent to the channel would be exposed to a potential transient hazard for less than 20 minutes. In 

addition, a temporary hazard would exist around the slip during part of the 24-hour period while the LNG 

vessel is maneuvering into the slip and at the dock unloading cargo. 

If the Coast Guard issues a LOR with conditions finding the waterway suitable for LNG marine 

traffic, the operational restrictions that would be imposed by the Pascagoula Pilots on LNG vessel 

movements through the area, as well as the requirements that the Coast Guard would impose in its LNG 

Vessel Transit Management Plan (see Section 4.12.5.2) would minimize the possibility of a hazardous 

event occurring along the vessel transit. 

Emergency Response and Evacuation Planning 

Prior to commencing operations, Bayou Casotte Energy would be required to prepare 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...” 

While the worst-case scenarios evaluated for the onshore facility in Section 4.12.4 and for marine 

spills in Section 4.12.5 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 will determine what area needs to be evacuated, if 

any, rather than a worst-case maximum zone. It is anticipated that the emergency evacuation plans will 

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, as 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 Emergency Response Plan prior to any final approval to begin construction. Therefore,

we recommend that:

• Bayou Casotte Energy develop emergency evacuation routes/methods for the areas 

along the route of the LNG carrier transit in conjunction with the local emergency 

planning groups and town officials and file the routes/methods with the Secretary for 

review and written approval by the Director or OEP prior to initial site preparation.

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In addition, we recommend that: 

• Bayou Casotte Energy should develop an 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 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; 

d. evacuation routes/methods for residents and other public use areas that are 

within any transient hazard areas along the route of the LNG vessel transit; 

e. locations of permanent sirens and other warning devices; and 

f. an “emergency coordinator” on each LNG carrier 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. Bayou Casotte Energy 

should notify FERC staff of all meetings in advance and should report progress on the 

development of its Emergency Response Plan at 3-month intervals. 

The 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 Cost-Sharing Plan 

that contains a description of any direct cost reimbursements the applicant agrees to provide to any state 

and local agencies with responsibility for security and safety at the LNG terminal and near vessels that 

serve the facility. To allow the FERC an opportunity to review the plan, we recommend that:

• The Emergency Response Plan should include a 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.

4.12.5.1 Pascagoula Bar, Horn Island Pass, Lower Pascagoula, and Bayou Casotte Channels 

The Port of Pascagoula in Mississippi Sound has two principal harbor areas: the Bayou Casotte 

(East) Harbor and the Pascagoula River (West) Harbor. Cargoes handled at the Port of Pascagoula 

include general, roll on-roll off, break bulk, and dry bulk, as well as bulk chemicals and crude oil in bulk. 

The East Harbor has ship repair and drill rig repair facilities, along with general cargo and liquid cargo 

terminals. The West Harbor has shipbuilding, drill rig repair, and general cargo facilities, along with U.S. 

Navy, NOAA, and Coast Guard activities. 

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If the Coast Guard issues a LOR finding the waterway suitable for LNG marine traffic with 

conditions (e.g., daylight transit, one way LNG vessel traffic), all LNG shipping would enter and depart 

the Mississippi Sound area by the Pascagoula Bar Channel, Horn Island Pass Channel, Lower Pascagoula 

Channel, and Bayou Casotte Channel. The length of each segment of the channel that would be traversed, 

and channel characteristics as they relate to marine safety, are summarized in Table 4.12.5-1. 

TABLE 4.12.5-1 

Channel Characteristics for Route that Would be Used by LNG Carriers Calling on the 

Proposed LNG Terminal 

Channel Segment Length 

(NM) Width (ft) Depth (ft) 

Pascagoula Bar Channel 3.3 450 44 

Horn Island Pass Channel 1.2 600 44 

Lower Pascagoula Channel 3.7 350 42 

Bayou Casotte Channel 4.4 350 42 

Total Length 12.6 

Upon reaching the LNG terminal, tugs would assist in slowing, turning, and maneuvering the 

LNG carrier into the mooring basin. Bayou Casotte Energy coordinated the design of this mooring basin 

using simulation studies with input from the Pascagoula Pilots and Chevron ship captains. Once the LNG 

carrier is turned with tug assistance, the ship would be maneuvered back and onto the LNG berth. The 

ship would be moored so that it points outward towards the Bayou Casotte Channel. This would allow 

ships to depart the LNG terminal without turning, which would provide for a more rapid emergency 

evacuation from the berth should this be required. 

Current Ship Traffic 

Vessel movements in Mississippi Sound are heavily dominated (numerically) by barge traffic, 

much of which transits to and from Pascagoula ports. Between 2000 and 2003, an average of 

5,065 vessels transited the Bayou Casotte Channel each year. Approximately 93 percent of these vessels 

consisted of vessels with a draft less than 18 feet: tug/tow, tanker, cargo, dry cargo barge, and tanker 

barge. The number of inbound large vessel transits in the Port of Pascagoula from July 2002 to June 2003 

and July 2003 to June 2004 was 485 and 556, respectively, or an average of 521 ships per year. About 

80 percent of that traffic went to Bayou Casotte, or an average of about 426 vessels per year. The 

dominant cargo commodity for vessels entering the port was crude oil calling at Chevron’s Pascagoula 

Refinery, with 303 and 397 ships, respectively, for those periods. Chevron’s refinery is located adjacent 

to the proposed Bayou Casotte Energy terminal. One of the refinery berths would be relocated into and 

on the north side of the proposed slip off the Bayou Casotte Channel. The next largest component was 

bulk carriers calling at the Mississippi Phosphates terminal located just north of the refinery, with 55 and 

42 vessel calls, respectively, for the two time periods. 

Future Ship Traffic 

The Marine Traffic Study performed by Moffatt & Nichol International for Bayou Casotte 

Energy provided data on existing vessel traffic that show a variable pattern of shipping volume. 

Assuming that future vessel traffic remains steady, the addition of up to 170 LNG carriers per year that 

would call on the proposed Casotte Landing LNG Terminal would result in an 47 percent increase in 

large vessel traffic (drafts greater than 18 feet), and a three percent increase in total vessel traffic. 

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Examining the shipping situation in the Port of Pascagoula with the combined impact of the 

proposed project (170 ships per year) and the Gulf LNG Project (150 ships per year, based on preliminary 

information available from Gulf LNG Energy LLC, Docket No. CP06-12-000), the total number of LNG 

carriers expected to call on the Port of Pascagoula would be is 320 ships per year. This would result in 

roughly one LNG carrier per day to one of the respective LNG terminals with a minimum of one transit 

per day and a maximum of two transits per day. Other shipping activities would be moderately affected 

by this increase in traffic; however, based on the relatively modest level of shipping activity in the Port of 

Pascagoula, the impact is not expected to be substantial. 

Ship Traffic in the Navigation Channels 

There are a number of factors that influence the movement of ship traffic in the Mississippi 

Sound Channels. These include: 

• Cross-Current – The COE-designated entrance channel extends from the end of the Horn 

Island Pass to the sea buoy. The cross-current is variable and can reach a velocity of 4 knots. 

However, the Pilots indicate a velocity of approximately 1.5 knots flowing commonly from 

west to east. The Pilots have to hold as much as 6 degrees of “leeway” on the vessel to 

counter the current. 

• Day Transit – Existing practice is for vessels with drafts greater than 36 feet to transit the 

channel only during daylight hours. According to the Pascagoula Pilots and the Coast Guard, 

LNG ship transit would only be allowed during daylight hours since the proposed LNG 

traffic would exceed the draft length restrictions. 

• One-way Traffic – One-way traffic is currently enforced within the channels that would be 

transited by the LNG vessels. In addition, a moving safety zone around LNG vessels would 

prohibit any passing of these vessels. 

• Reduced Visibility – Fog has the potential to eliminate all vessel movements. Visibility must 

be at least 2 nautical miles for vessels to travel inbound or outbound. Visibility is below the 

operational limits about six percent of the time; therefore, resulting in delays. 

• Tidal Range – The maximum annual tidal range is approximately 3.6 feet. That maximum 

range is most common in the face of very strong north winds or when there is a major storm 

in the Gulf of Mexico. The Pascagoula Pilots consider any conditions that create a tide range 

of 1.5 feet as something to take seriously. 

• Flood Tide/Ebb Tide – In general, flood tides typically set ships to the west, and ebb tides 

typically set them to the east. However, the set direction is not necessarily constant during 

the transit. The current changes directions several times as it flows around the islands and 

along the channel banks. 

• Wind – Inside the barrier islands of Mississippi Sound, the current is predominantly winddriven, often flowing across the channel. The current creates a moderate challenge to holding 

a ship in the channel, although at a lesser degree than what is experienced at the pass between 

the barrier islands. 

• Prevailing winds are anecdotally reported as being from south/southeast, although long-term 

wind data do not indicate a single overarching pattern. The Pascagoula Pilots have indicated 

that wind does not present a significant concern except during strong northers or coastal 

storms. Strong east or west winds, which have the most adverse impact on transit through the 

Pascagoula Channel, occur less than 10 percent of the time; however, when they do occur, 

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they could potentially create a challenging navigation situation in the relatively narrow 

channel. Under those conditions, large vessel transits would be delayed. 

• The Pascagoula Pilots have established a 15-knot wind speed limit for drill rig transits. Each 

transit of self-propelled vessels is evaluated individually and no cutoff has been established. 

• Pilot Availability – The Pascagoula Pilots operate with six fully-qualified, Coast Guardlicensed pilots and two apprentices. Apprentice pilots take up to 1 year to be qualified. The 

Pascagoula Pilots have two pilot boats. The Pascagoula Pilots have stated that their 

workforce would have to grow by at least two pilots to accommodate the traffic generated by 

Bayou Casotte Energy’s operations and that a larger more modern pilot boat would be 

necessary to allow them to continue to board the LNG vessels offshore under a wider range 

of operating conditions. 

• Tugs – If the Coast Guard issues a LOR finding the waterway suitable for LNG marine 

traffic, it is anticipated that LNG ships delivering cargo to the proposed terminal would have 

tug support for all maneuvering and berthing operations, at a minimum, and potentially have 

tug support for other phases of ship arrival and departure as well as standby and fire fighting 

duties during LNG unloading operations if so dictated by the Coast Guard COTP. There are 

currently five harbor tugs provided by Colle Towing Company. Two of these are tractor tugs 

rated at 4,000 hp and the remaining three are conventional tugs, one rated at 5,600 hp and two 

rated at 3,600 hp. In addition, a 5,600 hp tug is scheduled to join the fleet in the near future. 

Three tractor tugs, each with 5,300 hp, would be needed for the movement of LNG marine 

traffic within the shipping channel. The current fleet of tugs would not be able to safely 

accommodate the transit of LNG vessels to the proposed facilities. Bayou Casotte Energy 

has indicated that it would arrange for three tractor tugs to be readily available to prioritize 

the LNG marine traffic coming to port. These tugs would have adequate bollard pull to 

service the inbound and outbound movements expected at the proposed Bayou Casotte 

Energy LNG terminal. 

4.12.5.2 Requirements for LNG Carrier Operations in Port of Pascagoula 

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 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 ship 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 the communications, emergency shutdown, gas detection, and fire protection, must comply with 

the regulations in 33 CFR 127. Under 33 CFR 127.019, Bayou Casotte Energy would be required to 

submit two copies of its Operations and Emergency Manual 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 

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(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: 

• Density and character of marine traffic; 

• Locks, bridges, or other manmade obstructions in the waterway; 

• Environmental impacts of LNG marine traffic from territorial waters to the LNG facility 

berthing docks; 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 Captains of the Port/Federal 

Maritime Security Coordinators, 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, will also take completely into account maritime security implications. In accordance with this 

guidance, each LNG project applicant is to submit a Waterway Suitability Assessment (WSA) to the 

cognizant COTP. The WSA process addresses the transportation of LNG from an LNG tanker’s entrance 

into U.S. territorial waters, through its transit to and from the LNG receiving facility, including operations 

at the 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 Letter of Intent (LOI) to 

the Captain of the Port. In accordance with 33 CFR 127.007, Bayou Casotte Energy submitted a LOI to 

the Coast Guard on February 10, 2005 (see Appendix F). On November 17, 2005, the Coast Guard issued 

a notice in the Federal Register, requesting comments pertaining specifically to the maritime safety and 

security aspects of the proposed LNG facility. In preparation for issuance of a LOR and the completion 

of certain other regulatory mandates, the comments received were incorporated into a formalized risk 

assessment process to assess the safety and security aspects of the facility, adjacent port areas, and 

navigable waterways. The Coast Guard held a public meeting on December 7, 2005, pursuant to the 

notice. The Coast Guard’s comment period ended on December 14, 2005. 

If the Coast Guard issues a LOR finding the waterway suitable for LNG marine traffic with the 

conditions referenced in Section 2.0, the arrival, transit, cargo transfer, and departure of LNG marine 

traffic in the waterway would be required to adhere to the procedures of a LNG Vessel Transit 

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Management Plan to be developed by the Coast Guard Sector Mobile. In addition, Bayou Casotte Energy 

would develop Operations and Emergency Manuals in consultation with the Coast Guard. These 

procedures would be developed to ensure the safety and security of all operations associated with LNG 

ship transit and unloading. The LNG Vessel Transit Management Plan would contain specific 

requirements for the LNG ship, 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 Sector Mobile would monitor each LNG ship in accordance with the LNG 

Vessel Transit Management Plan. 

Some of the anticipated key provisions of the LNG Vessel Transit Management Plan would be 

the establishment of a moving safety and/or security zone for all inbound and moored LNG ships, and the 

use of tugs to assist in the channel and to maneuver the ship into the berth. Additional provisions may be 

necessary given changing circumstances. 

Bayou Casotte Energy Waterway Suitability Assessment (WSA) 

On February 13, 2006, Bayou Casotte Energy submitted a WSA for the proposed project to the 

Captain of the Port for Coast Guard Sector Mobile. The Coast Guard, with input from the Area Maritime 

Security Committee, has completed a review of Bayou Casotte Energy’s WSA in accordance with the 

guidance in NVIC 05-05. 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. 

Coast Guard Letter to FERC 

On April 1 and September 5, 2006, the Coast Guard sent WSR letters 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 (see 

Appendix G). As described in this document, the Coast Guard made a preliminarily determination that 

the Pascagoula Bar, Horn Island Pass, Lower Pascagoula and Bayou Casotte Channels may be suitable for 

the LNG marine traffic associated with this project with conditions. The Coast Guard also stated that 

these waterways can accommodate the proposed traffic and there is sufficient capability within the port 

community to responsibly manage the safety and security risks of this project. With the completion of 

this final EIS, the Coast Guard will complete its review and issue an LOR with conditions to address the 

suitability of the waterways for LNG transport. 

If the Coast Guard issues a LOR finding the waterway suitable for LNG marine traffic with the 

conditions referenced in Section 2.0, the necessary security measures would be further developed into a 

detailed LNG Vessel Transit Management 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 Pascagoula Bar, Horn Island Pass, Lower 

Pascagoula and Bayou Casotte Channels up to the proposed Bayou Casotte Energy 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 Captain of the Port in the LNG Vessel Transit Management Plan. The plan may 

include security measures such as: Coast Guard and other law enforcement agency vessels 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. 

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We recognize that the LNG Vessel Transit Management Plan would be a dynamic document that 

would be prepared well before import operations would commence, and that the port’s overall security 

picture may change over that time period. 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: 

• Bayou Casotte Energy should annually review its waterway suitability assessment 

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 Captain of the Port/Federal 

Maritime Security Coordinator (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. 

Impact of Vessel and Facility Security Requirements 

The potential impacts of the proposed LNG marine traffic for the Bayou Casotte Energy Project 

on other commercial and recreational boaters can be addressed in relation to several general security 

requirements: 1) a moving safety zone for inbound LNG marine traffic; 2) a security zone around a 

moored LNG vessel; and 3) other measures as deemed appropriate. 

If the Coast Guard issues a LOR finding the waterway suitable for LNG marine traffic, the Coast 

Guard may promulgate a moving safety zone that would affect other vessels. Pursuant to such a 

regulation, no vessel would be allowed to enter the safety zone without first obtaining permission from 

the Coast Guard Captain of the Port. If the Coast Guard issues a LOR finding the waterway suitable for 

LNG marine traffic, it is anticipated that the LNG marine traffic would transit about the 12.6 nautical 

miles from the entrance of the “HI” sea buoy to the proposed Bayou Casotte Energy terminal. For the 

majority of this trip, an LNG vessel would travel at an average speed of 10 knots. Based on these 

assumed speeds, it would take about 1 to 1.5 hours for LNG marine traffic to complete the trip from the 

sea buoy to the LNG terminal. Additional time would be required to maneuver the LNG ship into the 

berth. Minimum visibility conditions would have to be satisfied before the LNG ship would be allowed 

to proceed inbound from the Gulf of Mexico, ensuring that the Coast Guard could adequately monitor the 

safety zone. 

If moving safety zones, security zones at the terminal, and one-way traffic were implemented, 

they would affect other commercial and recreational traffic using the channel. The magnitude of the 

effect would also be influenced by other factors: the amount of time it takes to obtain a pilot and other 

competing ship traffic in the federal navigation channel. 

The moving safety zones, if implemented, may have the effect of temporarily limiting the channel 

to one-way traffic. This presently occurs with other large vessels that can sometimes delay other vessels 

using the waterway. It is expected that if the proposed LNG terminal is constructed, and if the Coast 

Guard issues a LOR finding the waterway suitable for LNG marine traffic, as many as 170 LNG ships for 

the Bayou Casotte Energy terminal could potentially move in and out of the Pascagoula Bar, Horn Island 

Pass, Lower Pascagoula and Bayou Casotte Channels every year. This is an increase in vessel traffic of 

47 percent for large vessels per year currently transiting these waterways. Other shipping activities would 

be moderately affected by this increase in traffic; however, based on the relatively modest level of 

shipping activity in the Port of Pascagoula, the impact is not expected to be substantial. 

The moving safety zone could cause impacts on recreational and other commercial vessels but the 

impacts would be temporary while the LNG vessel is in transit or moored at the unloading facility. 

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Because the safety zone would be a moving zone around the ship, the impacts would be of short duration 

at any given point along the shipping route. A recreational craft attempting to travel in the opposite 

direction of an LNG ship traveling at 10 knots may need to wait up to 15 minutes for the LNG ship to 

pass before proceeding on its way. The delay would increase to up to 36 minutes when the LNG ship is 

traveling at 5 knots and up to 60 minutes when the LNG ship is traveling at 3 knots. For other vessels 

near or upstream of the facility, an additional 60-minute delay may be experienced while the LNG ship is 

berthed. It should be noted that the Coast Guard moving safety and moored vessel security zones 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 and moored vessel security zones with the 

permission of the Captain of the Port. 

Additionally, any moving safety zone regulation that may be promulgated by the Coast Guard 

would affect a moving zone around the ship, so these impacts would be temporary and of short duration at 

any given point along the shipping route. In addition, depending on their individual drafts, commercial 

and recreational vessels might be able to go around the LNG marine traffic at points in the waterway that 

are sufficiently wide for them to be outside of any moving safety zone. If the Coast Guard issues a LOR 

finding the waterway suitable for LNG marine traffic, to mitigate any adverse impacts of moving safety 

zone, the Coast Guard may routinely provide Notice to Mariners prior to the arrival and departure of LNG 

marine traffic. The notification system includes broadcasts on radio frequencies used by mariners. These 

practices and impacts currently occur in other waterways during LNG vessel transits. 

The Coast Guard made a preliminarily determination that if appropriate resources were available 

to implement certain necessary security measures, the Pascagoula Bar, Horn Island Pass, Lower 

Pascagoula and Bayou Casotte Channels could accommodate the number of LNG carriers that would 

supply the proposed Bayou Casotte Energy LNG terminal. This determination is preliminary because the 

required NEPA analysis has not yet been completed. This determination is also contingent upon the port 

security community having the appropriate resources to implement all the measures necessary to 

responsibly manage the safety and security risks of LNG marine traffic in this area. If the Coast Guard 

issues a LOR finding the waterway suitable for LNG marine traffic, in addition to the moving safety and 

security zones around the LNG marine traffic, the LNG Vessel Transit Management Plan to be developed 

by the Coast Guard Sector Mobile, would minimize impact to other ship traffic, escorts by armed law 

enforcement officials, and waterway and shoreline surveillance measures. 

The FERC has received comments on other LNG terminal proposals expressing concern about 

the cost of applying additional security measures and the potential burden on local taxpayers. To meet its 

anticipated security responsibilities the Coast Guard most likely would need to request additional 

resources through its internal resource reprogramming process for inclusion in future appropriations. 

Additional funding for state and local resources would be provided by Bayou Casotte Energy to the extent 

called for by the Cost-Sharing Plan to be developed with the pertinent state and local agencies. In order 

to precisely determine the additional resources that would be necessary to provide the additional security 

to ensure safe transit of the LNG marine traffic, it would be necessary to develop and finalize the Coast 

Guard’s LNG Vessel Transit Management Plan. Funding for security and management costs are 

discussed further in Section 4.12.5 “Emergency Response and Evacuation Planning”. 

While the LOR would address the suitability of the Pascagoula Bar, Horn Island Pass, Lower 

Pascagoula and Bayou Casotte Channels for LNG ship transportation; it would not constitute a final 

authority to commence LNG operations. The Coast Guard’s recommendation is subject to certain safety 

and security provisions to be developed in its LNG Vessel Transit Management Plan, as well as other 

possible conditions discussed in Section 2.0. This plan would be reviewed and updated as necessary to 

address issues specific to the waterway and the proposed LNG terminal. In addition, the Coast Guard 

may establish a safety and security zone under 33 CFR 165 for LNG vessels in transit and while docked. 

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Only personnel or vessels authorized by the Captain of the Port would be permitted in the safety and 

security zone. 

4.12.5.3 Environmental Impacts Associated with Coast Guard Actions 

The Coast Guard's issuance of a LOR is a federal action that requires compliance with NEPA, 

just as the FERC's authorization for construction and operation of a LNG facility requires compliance 

with NEPA. Alternatives regarding these actions are discussed in Section 3. 

Some of the potential environmental impacts resulting from LNG vessel activities and transit 

would not be unique to LNG marine traffic and may also be addressed by previous Coast Guard NEPA 

analyses for existing regulations. Per the Coast Guard NVIC 05-05, all required Coast Guard NEPA 

analysis and documentation must be complete prior to the issuance of any LOR. 

Potential impacts from LNG marine transit, including support vessels and any required Coast 

Guard or other law enforcement security escort or patrol vessels, on wildlife and aquatic resources are 

discussed in Sections 4.5 and 4.6. The potential impacts that result from LNG carriers in transit would be 

similar to those resulting from other ships using the navigation channel. Impacts include those related to 

prop wash, invasive species, and water withdrawal for ballast and cooling. Although no significant 

impacts on wildlife or aquatic resources a result of LNG marine traffic is expected, we recommend in 

Section 4.5.2.2 that Bayou Casotte Energy continue to consult with federal and state agencies to 

determine the need for mitigative measures to avoid or minimize impacts on aquatic resources as the 

result of LNG ship ballast and cooling water intakes. 

LNG marine traffic, support vessels, and security escort and patrol vessels would emit criteria 

pollutants, VOCs and HAPS during transit. We have identified the magnitude of these emissions in 

Section 4.11.1.4. The proposed project would be located in an attainment area. Therefore, the General 

Conformity requirements do not apply. 

The LNG carrier would be operating in the federally approved channels en route to the terminal. 

We believe the use of these channels is consistent with the Mississippi CMP; however, consistency with 

this plan would be determined by the State of Mississippi. The coastal effects associated with the 

proposed Project, including coastal effects resulting from LNG carrier transit, are addressed in Section 

4.7.3 to the extent this statute is applicable. As such, consistency with the CZMA is required as 

appropriate. We have recommended as a condition in Section 4.7.5 that Bayou Casotte Energy submit 

documentation of concurrence from the MDMR that the project is consistent with the Mississippi CMP. 

The potential impacts associated with a release of LNG are discussed generally in the preceding 

and following sections. The establishment of temporary safety and security zones by the Coast Guard has 

been considered as a potential effect on recreational use of the waterway (see Section 4.7.3.4). However, 

we do not expect these zones to have a significant effect on environmental resources. 

As a linear feature, the LNG transit route transects an assemblage of varying socioeconomic 

character determined by the presence of the waterway or other adjacent features. Furthermore, the 

shipping route used by LNG marine traffic is not discretional. That is, the route was developed prior to 

the concept of its use for LNG traffic and alternative routes are not available. Therefore, it is not possible 

to determine the vessel transit corridor based on environmental justice considerations. 

The transit corridor for the LNG marine traffic would traverse open water and estuarine habitats. 

Approximately 8.6 miles of the transit corridor are within confined waters between the barrier islands and 

the mainland, where shoreline could be affected by accidental spills. The aquatic and shoreline habitats 

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support a variety of wildlife which are described in Section 4.5 and 4.6. Figure 4.12.5-1 shows the 

potential extent of hazard distance from an accidental spill, the locations of significant parks, refuges, and 

other public recreation areas along the transit corridor. 

LNG is less dense than fresh or seawater, so it floats on the surface. Immediately upon contact 

with any warmer substance such as water or air, it begins to evaporate. As the LNG vaporizes, a vapor 

cloud may form which is initially heavier than air and may be dispersed by wind. A LNG vapor cloud 

cannot explode in the open atmosphere, but it could burn. 

Since LNG is a cryogenic liquid, the greatest threat to aquatic life from an LNG spill would be 

thermal stress. Any aquatic life (including plankton, fish, birds, sea turtles, marine mammals, and any 

federally-listed species) that came into direct contact with the LNG would probably experience a sudden 

cold shock, and, depending in what context that contact occurred, the exposure could be lethal, especially 

to non-motile species. Most mobile underwater organisms would detect the temperature change and 

avoid the area. Wildlife occupying the water’s surface near the release could intercept the vapor cloud 

and suffer asphyxiation. However, the duration of this exposure is short, as noted below. Impacts to 

shoreline habitats and associated wildlife could occur, primarily, through the subsequent ignition of the 

LNG. The potential damage could involve the combustion of both vegetation and wildlife. 

The accident scenarios evaluated in Section 4.12.5.4 include release and ignition of natural gas 

formed by evaporation of spilled LNG. Natural gas combustion typically is not complete in spill 

scenarios. The products of incomplete combustion of natural gas include criteria pollutants, ozone 

precursors, toxic air contaminants, and soot (carbon particulates). It should be noted that LNG fires 

typically do not last as long as liquid petroleum fires. 

The duration of an ignited accidental LNG spill detailed in Table 4.12.5-3 is approximately 

48 minutes. For an ignited intentional LNG spill, the duration is approximately 11 minutes. The 

maximum increases in ambient pollutant concentrations due to the natural gas fire would occur downwind 

of the LNG spill. Ambient air pollutant concentrations in downwind areas could potentially exceed shortterm 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. Given the distance to shore from a potential 

fire from most of the transit route along the Port of Pascagoula Channels, it is unlikely that sensitive 

receptors (i.e., schools, day care centers, hospitals, retirement homes, convalescence facilities, and 

residences) would be exposed to substantial pollutant concentrations for a significant period. Furthermore, 

the shoreline areas nearest the transit channels are generally vacant or industrial. If more populated areas 

were to be exposed to higher pollutant concentrations for the short duration of the fire, the effects would 

be short term. 

The pool formed from an unignited accidental LNG spill would completely evaporate in 

approximately 94 minutes. For an ignited intentional LNG spill, the pool would completely evaporate in 

approximately 7 minutes. As natural gas is not a criteria pollutant, no air quality impacts would be 

expected from the evaporation of the LNG spill. However, methane, the primary component of LNG, is 

considered a greenhouse case and may contribute to global warming (Coast Guard, 2005). 

However, the history of LNG shipping has been free of major incidents, and none have resulted in 

significant quantities of LNG being released. No incidents have occurred at existing LNG terminals 

during the 50 years of operation that resulted in any significant quantities of cargoes being released. 

Historically, the events most likely to cause a significant release of LNG were ship casualties such as 

collisions, allisions, or groundings. Any event causing a release of LNG would have to occur with 

sufficient impact to breach the LNG ship’s double hull and cargo tanks. During the 44,000 voyages that 

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Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Page 4-146 

Figure 4.12.5-1 Proposed Casotte Landing Project 

Potential Sensitive Resources Along Ship Route 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

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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. Based on the 

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

operational controls that may be imposed by the Coast Guard and local pilots, the likelihood of a cargo 

containment failure and subsequent LNG spill from a vessel casualty – collision, grounding, or allision – 

is highly unlikely. However, the possibility of an LNG spill from a ship over the duration of the proposed 

Project must be considered. 

Given that a LNG cargo spill is highly unlikely, no significant socioeconomic impact associated 

with an accidental LNG release along the transit route would be expected. As described below, the 

duration of a LNG pool fire would be of short duration (i.e., from 1 to 2.5 hours). If an LNG spill 

occurred along the transit route, ship traffic may be temporarily interrupted in the navigation channel; 

however, traffic in the navigation channel would quickly resume normal operations and any economic 

impact on the maritime industry would be minimal. 

If a pool fire occurred where the transit route is closer to shore, structures within 2,200 feet of the 

center of a spill could be subject to a long-term loss of use. Vegetation and wooden structures subjected 

to greater than 3,000 Btu/ft2

-hr5 may ignite. However, because the hazard area surrounding an LNG 

cargo vessel is transient (moving with the vessel along its route) it is not possible to accurately quantify 

the economic impact of an incident. Section 4.12.5.4 discusses the effects of a LNG spill in greater detail. 

In accordance with Section 3A(e) of the Natural Gas Act, added by Section 311 of the Energy 

Policy Act of 2005, we recommend in Section 4.12.5 that Bayou Casotte Energy develop an Emergency 

Response Plan in consultation with the Coast Guard and state and local agencies that includes a Cost 

Sharing Plan before any final approval to begin construction. Therefore, no long-term impacts related to 

emergency evacuation of communities would be expected. 

As discussed in Section 4.12.5, “Deliberate Attack on an LNG Vessel,” the December 2004 

Sandia Report included an analysis of potential LNG cargo tank breaches due to accidental causes. The 

report found that accidental groundings, collisions with small vessels, and low speed collisions with large 

vessels could cause minor ship 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. 

We do not believe that these types of accidents would be environmentally significant. 

High speed collisions with large vessels striking at 90 degrees were found to potentially cause 

cargo tank breach areas of 0.5 to 1.5 square meters. For the resulting LNG spill and pool fire on water, 

the Sandia Report determined that the most significant impact on public safety and property would exist 

within about 800 feet, with minimal impact beyond 2,400 feet. Depending on the actual size of the cargo 

tank breach, the duration of the spill and ensuing pool fire could range from approximately 1 to 2.5 hours. 

Using the methodology in the ABSG study, FERC staff determined that the site-specific distance to the 

1,600 Btu/ft2

-hr transient hazard area for an accidental cargo tank breach in the Pascagoula Bar, Horn 

Island Pass, Lower Pascagoula, and Bayou Casotte Channels would be approximately 2,790 feet. 

In the unlikely event of an LNG spill, the physical properties of LNG would limit any potential 

impacts. If spilled into water, the cryogenic liquid would vaporize rapidly upon contact with the warm air 

and water over a period of approximately 1 to 2.5 hours. Being less dense than water, LNG would float 

 

5

 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. 

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on the surface prior to vaporizing. Because LNG is not soluble in water and the LNG would completely 

vaporize shortly after being spilled, there would be no liquid left that could mix with and/or contaminate 

the water. 

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 the unlikely event that 

ignition did not occur, an LNG spill would rapidly vaporize on water and form a potentially flammable 

cloud. If the flammable vapor cloud encountered an ignition source, the cloud would burn back to the 

spill site, rather than outward towards shoreline habitats. 

Given these considerations, impacts on shoreline habitats as a result of an accidental LNG spill 

are unlikely to occur. A spill would be unlikely to result in significant impacts on shoreline habitats and 

wildlife that occur along the transit route. Hazard distances for intentional breaches are discussed in 

Section 4.12.5.4. Although an intentional breach scenario may result in greater hazard distances, such 

scenarios are associated with the desire to inflict damage to major infrastructure, population, and 

commercial centers, rather than to environmentally sensitive areas along the vessel route. Also, given the 

navigation controls and safety and security procedures in place to specifically prevent such accidents and 

intentional spill scenarios, the indirect impact associated with Coast Guard actions are not reasonably 

foreseeable events. 

As discussed in Section 4.12.5.2, if the Coast Guard issues an LOR finding the waterway suitable 

for LNG marine traffic with the conditions referenced in Section 2.0, the Coast Guard may establish a 

moving safety zone, moored vessel security zone, and/or a regulated navigation area around the transiting 

LNG vessels and provide some level of escort as part of finalizing the LNG Vessel Traffic Management 

Plan. The LNG vessels would also undergo safety and security inspections to ensure compliance with 

United States and international standards. In addition, the LNG facility would submit a facility security 

plan for review and approval by the Coast Guard. However, due to uncertainty in the scope, frequency, 

prevailing maritime security levels, and the number of resources that would be dedicated on a recurring or 

episodic basis, the Coast Guard would ensure the appropriate NEPA environmental documentation for 

such actions is complete prior to commencement of these activities rather than in this EIS. 

4.12.5.4 LNG Carrier Safety 

Since 1959, LNG has been transported by ship without a major release of cargo or a major 

accident involving an LNG ship. 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, an estimated total of 631 billion 

cubic feet (241 cargoes) of LNG was imported into the United States. For 35 years, LNG shipping 

operations have been safely conducted in the United States. The world's LNG ship fleet currently exceeds 

173 carriers. 

Over the last 45 years, LNG ships have made over 44,000 voyages. Currently, all of the ships in 

the LNG fleet operate under a foreign flag with foreign crews. A foreign flag ship must have a Certificate 

of Compliance inspection by the Coast Guard to ensure compliance with International safety standards. 

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 marine traffic, including minor collisions with other vessels of all 

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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 carrier and delivered to 

its U.S. 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 

ship 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 from its docking berth at Skikda, Algeria in February 1989 during severe 

winds causing damage to the loading arms and the ship 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 

fracturing of some of the plating. 

• Mostafa 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 ship was required to 

discharge its cargo, after which it proceeded to dock for repair. 

• Khannur had a cargo tank overfill into the ship’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 rising to 

periscope depth near the Strait of Gibraltar in November 2002. The 87,000 m3

 LNG tanker, 

which had just unloaded its cargo at Barcelona, Spain, sustained only minor damage to the 

outer layer of its double hull but not 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 ship 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. 

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Vessel Construction 

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 carriers 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 carriers to prevent or control all types of potential incidents. 

The insulation of cargo tanks on LNG carriers is a complex assembly of many layers. The relief 

valve capacity of cargo tanks is designed to compensate for over-pressure caused by fire. The potential 

that impingement by a cryogenic liquid could cause brittle fracture of the ship’s hull was known to the 

Coast Guard in the mid-1970s when the U.S. regulation for LNG carriers in 49 CFR 154 were being 

developed. LNG carriers used in the U.S. waters must also be constructed in accordance with the IMO 

Code for the Construction and Equipments of Ships Carrying Liquefied Gases in Bulk. This standard 

requires that the vessel inner hull adjacent to the cargo tanks be protected against contact from liquid 

cargo through a combination of proper material selection, adequate insulation, and use of heating systems. 

As required by the IMO conventions and design standards, hold spaces and insulation areas on an 

LNG ship 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 carriers 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 abovedeck. A water spray system is also available for cooling, fire prevention, and crew protection in specific 

areas. In addition, certain areas of LNG carriers are fitted with dry chemical powder-type extinguishing 

systems and CO2 smothering systems for fighting fires. 

Unlike many conventional crude oil tankers, all LNG carriers used to deliver LNG to this 

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 tanker would be unable to penetrate both inner and outer hulls of an LNG carrier. 

An earlier Federal Power Commission (FPC, predecessor to the FERC) study estimated that the doublebottom of an LNG carrier would be sufficient to prevent cargo tank penetration in about 85 percent of the 

cases that penetrated a single-bottom oil tanker. 

The probability of an LNG carrier 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 the additional protection afforded by the double-hull would be 

effective in low energy collisions, and overall it would prevent cargo tank penetration in about 25 percent 

of the cases that penetrated a single-hull oil tanker. 

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 tanker striking an LNG carrier at berth (FERC, 1996). 

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The analysis assumed a 125,000 cubic meter LNG carrier and an 82,000 dead weight ton tanker carrying 

number 6 fuel oil without tug assistance. The analysis determined the minimum striking speed to 

penetrate the cargo tanks of an LNG carrier for a range of potential collision angles. The resulting 

minimum striking speeds are presented in Table 4.12.5-2 for the two principal cargo systems. 

TABLE 4.12.5-2 

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 

45 Degrees 6.3 4 

30 Degrees 9 6 

15 Degrees 18 12 

For membrane tanks, the critical beam-on striking speed is 3.0 knots, and for spherical tanks, the 

critical on-beam 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 shows the critical speed necessary for 

a 20,000-ton vessel to puncture the outer hull of an LNG carrier is 7.3 knots. For a 93,000-ton ship, the 

impact speed is 3.2 knots. In neither case does such an impact result in damage to the LNG cargo 

containment system or the release of LNG. 

In December 2004, the DOE release a study by Sandia National Laboratories, Sandia Report. 

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. 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 ship 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 square meters. 

Hazards 

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 under water and the 

potential for ignition would be less than for collisions or allisions. In this case, an LNG spill would 

rapidly vaporize from contact with 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 lower flammable limit for methane. The maximum range of potentially flammable vapors (the 

distance to the lower flammable limit) is a function of the volume of LNG spilled, the rate of the spill, and 

the 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 (Lake Charles, LA) (September 1976) analyzed the 

maximum range of a flammable vapor cloud and hazardous radiation levels from an instantaneous onetank spill. As was consistent with risk analyses at that time and for nearly 25 years thereafter, the 

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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/hr-ft2

 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, March 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. 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 only applied to 

LNG spills resulting from a collision with a large ship in Boston’s Outer Harbor where waves would 

restrict the spreading of LNG on water. 

In the 2001 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 carrier 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 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 carrier cargo releases during 

transit and while at berth. The resulting 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. As 

discussed in greater detail in staff’s responses, various components of the consequence assessment 

methodologies were revised based on comments received. In addition, the model was updated to include 

a lower limit on the characteristic wind speed. The revised study provides the methodology 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) and flammable vapor dispersion distances. 

A detailed evaluation of the consequences of a terrorist attack on a modern membrane LNG 

tanker was prepared by Lloyds Register North America for the Weaver’s Cove LNG Project and filed 

under CEII. The study evaluated the consequences of attacks on an LNG tanker by missiles and 

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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 

average most probable “worst case” scenario for hazard consequence assessments. This finding is 

consistent with the attack on the double-hull oil tanker 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 used 

to investigate damage scenarios for a loaded LNG tanker. 

The December 2004 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. The analysis of accidental events found that 

groundings and low speed collisions could result in minor ship damage but not a cargo spill; while high 

speed collisions could cause a 0.5- to 1.5-square meter cargo tank breach area. For intentional scenarios, 

the size of the cargo tank hole depends on the location of the ship and source of threat. Intentional breach 

areas were estimated to range from 2 to 12 square meters. In most cases, an intentional breaching 

scenario would not result in a nominal hole of more than 5 to 7 square meters, which is a more 

appropriate range to use in calculating potential hazards from spills. 

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 (5,250 feet). Large, unignited LNG vapor releases were found to be 

unlikely, but could extend to 2,500 meters (8,200 feet) for a nominal intentional spill. 

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 or 6,300 to 6,825 feet), but would increase 

the expected fire duration. RPTs are 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 

used 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 typical 

140,000 m3

 LNG carrier, 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 4.12.5-3 below. Thermal radiation calculations are based on an ambient temperature of 50°F, a 

relative humidity of 50 percent, and a 20-mile per hour wind speed. 

However, Bayou Casotte Energy proposes the potential use of up to a 200,000 cubic meter LNG 

ship. The limited information available regarding the design of future 200,000 cubic meter LNG ships 

suggests that the draft of the larger ships would remain the same due to the limited draft of the channel, 

while the length and width of the larger ships would increase. This would in effect increase the length 

and width of the cargo tanks, but not change the height, therefore no change the hydrostatic head. 

Preliminary information shows that the larger class ships would have five cargo tanks instead of four as 

on the 140,000 cubic meter ships. For a 200,000 cubic meter LNG ship compared to the results for a 

140,000 cubic meter LNG ship, the estimated distance to the 1,600 Btu/ft2-hr zone would be less than 

2 percent farther and the fire duration would be extended by about 13 percent. 

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TABLE 4.12.5-3 

LNG Spills on Water 

LNG Release and Spread 

Hole Diameter 1.0 m 1.4 m 2.5 m 3.0 m 3.9 m 

Hole Area 0.8 m2 1.5 m2 5 m2 7 m2 12 m2

Spill Time 94.0 min 48.0 min 15.0 min 10.4 min 6.2 min 

Pool Fire Calculations 

Maximum Pool Radius 341 ft 476 ft 817 ft 938 ft 1,102 ft 

Fire Duration 94.1 min 48.1 min 15.2 min 10.7 min 6.5 min 

Distance to: 

1,600 Btu/ft2-hr 2,164 ft 2,790 ft 4,182 ft 4,652 ft 5,250 ft 

3,000 Btu/ft2-hr 1,690 ft 2,169 ft 3,232 ft 3,591 ft 4,047 ft 

10,000 Btu/ft2-hr 1,031 ft 1,312 ft 1,934 ft 2,143 ft 2,409 ft 

Although Bayou Casotte Energy would design the terminal and unloading berth for LNG ships 

with capacities up to 200,000 cubic meters, detailed dimensions of these future ships and the associated 

cargo tanks is unavailable. FERC staff was required to make assumptions in order to analyze the LNG 

spills on water from these larger ships. Therefore, in order to allow the Coast Guard to determine the 

continued suitability of the waterway for LNG marine traffic, we recommend that: 

• Prior to accepting ships greater than 140,000 cubic meters in capacity, Bayou Casotte 

Energy should provide the necessary information to demonstrate that the transient 

hazard areas identified in the final EIS are applicable. Bayou Casotte Energy should 

file this information with the Secretary for review and written approval of the Director 

of OEP. This information should also be provided to the Coast Guard in a new LOI 

and a new LOR would need to be evaluated. 

Flammable vapor dispersion calculations were based on an ambient temperature of 70oF, 

50 percent relative humidity, a 4.5-mph wind speed and atmospheric stability Class F. Based on a 1-

meter diameter hole, an unignited release would result in an estimated pool radius of 421 feet. The 

unignited vapor cloud would extend to 9,776 feet to the LFL and 14,377 feet to one-half the LFL. It is 

important to identify certain key assumptions of conditions that must exist in order to achieve the 

maximum 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 its maximum distance over land surfaces without 

encountering an ignition source, and subsequently burning back to the source. Flammable vapor 

dispersion for larger holes was not performed since, realistically, the cloud would not even extend to the 

maximum distance for a 1-meter diameter hole before encountering an ignition source. 

The entire from the Gulf of Mexico through the Pascagoula Bar, Horn Island Pass, Lower 

Pascagoula, and Bayou Casotte Channels to the LNG berth, has no development or communities adjacent 

to the channel or within the 4,652 feet transient hazard area. Assuming an LNG vessel would transit 

through the channel between at 3 and 10 knots, areas adjacent to the channel would be exposed to a 

potential transient hazard for less than 20 minutes. In addition, a temporary hazard would exist around 

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the slip during part of the 24-hour period while the LNG vessel is maneuvering into the slip and at the 

dock unloading cargo. 

In addition, the potential impact on the infrastructure and industrial development 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 following infrastructure and industry within approximately 

2,143 feet to a thermal radiation level of 10,000 Btu/ft2-hr for 10- to 15-minutes: the marine berth of the 

proposed Gulf LNG Energy LLC terminal currently under FERC review; and a portion of Chevron’s 

Pascagoula refinery (marine berths and crude storage tanks). In addition, a fire associated with a potential 

spill in the vicinity of Bayou Casotte Energy’s berth resulting from a nominal cargo tank hole of an 

intentional event could expose the process area and the proposed LNG storage tanks to a thermal radiation 

level of 10,000 Btu/ft2-hr for 10- to 15-minutes. 

The operational restrictions that would be imposed by the Pascagoula Pilots on LNG vessel 

movements through this area, as well as requirements that the Coast Guard would impose in its LNG 

Vessel Transit Management Plan, would minimize the possibility of a hazardous event occurring along 

the vessel transit. 

By focusing on the “worst case” intentional breach scenarios 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 “worst case” scenarios provide guidance in 

developing the operating restrictions for LNG vessel movements in the Port of Pascagoula Channels, as 

well as in establishing potential impact areas for emergency response and evacuation planning. 

4.12.5.5 Conclusions on Marine Traffic Safety 

The operational safety of LNG marine traffic is under the jurisdiction of the Coast Guard. LNG 

carriers have safely transited another 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 determining suitability 

of the waterway for LNG marine traffic with conditions, operational restrictions that may be imposed by 

the Coast Guard and the Pascagoula 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 of Pascagoula channels. With the mitigation measures discussed above, the operation of LNG ships 

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. 

4.12.6 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 

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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 ships to provide them with a 96-hour advance notice of arrival that includes key 

information about the vessel and its crew which allows the Coast Guard to conduct a terrorism risk 

assessment and put in place appropriate mitigation before the ship reaches the ship 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. 

In September 2002, the DOT's OPS issued non-public guidelines to LNG operators that direct 

them to develop new security procedures for onshore facilities. Operators were required to prepare a 

security plan within 6 months that responds to the five threat levels defined by the Office of Homeland 

Security. The OPS conducts subsequent on-site reviews of the security procedures. 

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 acknowledges 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; 

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• 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, prevent 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, 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 LNG import terminal, or at any of the 

myriad natural gas pipeline or energy facilities throughout the United States is unpredictable given the 

disparate motives and abilities of terrorist groups. 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. 

4.12.7 Pipeline Facilities 

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. 

4.12.7.1 Safety Standards 

The DOT is mandated to provide pipeline safety under Title 49, U.S.C. Chapter 601. The 

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 

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which set the level of safety to be attained and allow the pipeline operator to use various technologies to 

achieve safety. The 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 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 Casotte Landing Project must be 

designed, constructed, operated, and maintained in accordance with the DOT Minimum Federal Safety 

Standards in 49 CFR Part 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 on at least 5 days a week for 10 weeks in any 12-month period. 

Class 4 Location where buildings with four or more stories aboveground are prevalent. 

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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 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. 

Class locations also specify the maximum distance to a sectionalizing block valve (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, maximum allowable operating pressure, inspection 

and testing of welds, and frequency of pipeline patrols and leak surveys must also conform to higher 

standards in more populated areas. The proposed pipeline interconnect routes would cross open land that 

is sparsely populated. Project natural gas laterals are 1.5 miles or less and no high consequence areas are 

located within 220 yards. Due to the industrial location and proximity to the Pascagoula Refinery, the 

Project’s natural gas pipeline laterals would be in Class 1 areas. 

If a subsequent increase in population density adjacent to the right-of-way indicates a change in 

class location for the pipeline, Bayou Casotte Energy would be required to reduce the maximum 

allowable operating pressure 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 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. No later than December 17, 2004, gas transmission 

operators must develop and follow a written integrity management program that contains all the elements 

described in §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 Federal Register 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 §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 U.S.C. 60109 for OPS to prescribe standards that establish criteria 

for identifying each gas pipeline facility in a high-density population area. 

The HCAs 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 radius6

 is greater than 660 feet and there 

are 20 or more buildings intended for human occupancy within the potential impact circle7

; or 

 

6 The potential impact radius is calculated as the product of 0.69 and the square root of the maximum allowable 

operating pressure of the pipeline in psi multiplied by the pipeline diameter in inches. 

7

 The potential impact circle is a circle of radius equal to the potential impact radius. 

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• any area in Class 1 or 2 where the potential impact circle includes an identified site.8

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 HCAs. The DOT regulations 

specify the requirements for the integrity management plan at § 192.911. 

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. 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 

• protecting people first and then property, and making them safe from actual or potential 

hazards. 

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. Bayou Casotte Energy would provide the appropriate training to local emergency service 

personnel before the pipeline is placed in service. No additional specialized local fire protection 

equipment would be required to handle pipeline emergencies. 

 

8

 An identified site is an outside area or open structure that is occupied by 20 or more persons on at least 50 days 

in any 12-month period; a building that is occupied by 20 or more persons on at least 5 days a week for any 10 

weeks in any 12-month period; or a facility that is occupied by persons who are confined, are of impaired mobility, 

or would be difficult to evacuate. 

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4.12.7.2 Pipeline Accident Data 

Since February 9, 1970, 49 CFR Part 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 4.12.7-1 

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.9

TABLE 4.12.7-1 

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 

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. 

 

9

 Jones, D.J., G.S. Kramer, D.N. Gideon, and R.J. Eiber, 1986. "An Analysis of Reportable Incidents for Natural 

Gas Transportation and Gathering Lines 1970 Through June 1984." NG-18 Report No. 158, Pipeline Research 

Committee of the American Gas Association. 

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Additional insight into the nature of service incidents may be found by examining the primary 

factors that caused the failures. Table 4.12.7-1 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. 

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 4.12.7-2 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 (for example, 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 show that the portion of 

incidents caused by outside forces has decreased to 38.5 percent. 

TABLE 4.12.7-2 

Outside Forces Incidents by Cause (1970-1984) 

Cause Percent 

Equipment operated by outside party 67.1 

Equipment operated by or for operator 7.3 

Earth movement 13.3 

Weather 10.8 

Other 1.5 

The pipelines included in the data set in Table 4.12.7-1 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 4.12.7-3 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 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. 

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TABLE 4.12.7-3 

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 

4.12.7.3 Impact on Public Safety 

The service incident data summarized in Table 4.12.7-1 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 4.12.7-4 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 shows 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 4.12.7-4 

Annual Average Fatalities - Natural Gas Transmission and Gathering Systemsa b

Year Employees Nonemployees Total 

1970-June 1984 2.4 2.6 5.0 

1984-2005c - - 3.6 

1984-2005c - - 2.8d

____________

NOTE: 

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 

7 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 4.12.7-5 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 categories. Nevertheless, the average of 

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 

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magnitude (100 times) lower than the fatalities from natural hazards such as lightning, tornadoes, floods, 

and earthquakes. 

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, the Casotte Landing Project might result in a public fatality every 66,667 years. This 

would represent a slight increase in risk to the nearby public. 

TABLE 4.12.7-5 

Nationwide Accidental Deathsa

Type of Accident Fatalities 

All accidents 90,523 

Motor vehicles 43,649 

Falls 14,985 

Drowning 3,488 

Poisoning 9,510 

Fires and burns 3,791 

Suffocation by ingested object 3,206 

Tornado, flood, earthquake, etc. 

 (1984-93 average) 181 

All liquid and gas pipelines 

 (1978-87 average) b 27 

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 U.S. 118th Edition." 

b

 U.S. Department of Transportation, "Annual Report on Pipeline Safety - Calendar Year 1987." 

c

 American Gas Association, 1986. 

4.12.8 Conclusions on Safety Issues 

Much of the recent safety debate has centered on the perceived size of worst case scenarios; the 

distance to various thermal radiation heat levels for LNG fires; the range of potentially flammable vapors; 

and the population and infrastructure that are located within the various hazard areas. These are 

components of a consequence analysis. 

However, the evaluation of safety is more than an exercise in calculating the consequences of 

worst case scenarios. Rather, safety is a determination of the acceptability of risk which considers: (1) the 

probability of events; (2) the effect of mitigation; and (3) the consequences of events. 

• Accidental Causes - Based on the extensive operational experience of LNG shipping, the 

structural design of an LNG carrier, and the operational controls that may be imposed by the 

Coast Guard and the local pilots, the likelihood of a cargo containment failure and subsequent 

LNG spill from a vessel casualty – collision, grounding, or allision – is highly unlikely. For 

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similar reasons, an accident involving the onshore LNG import terminal is unlikely to affect 

the public. As a result, the risk to the public from accidental causes should not be considered 

significant. 

• Intentional Attacks - Unlike accidental causes, historical experience provides little guidance 

in estimating the probability of a terrorist attack on an LNG carrier or onshore storage 

facility. For a new LNG import terminal proposal, having a large volume of energy 

transported and stored near populated areas, the perceived threat of a terrorist attack may be 

considered as highly probable to the local population. 

However, at the national level, potential terrorist targets are plentiful, many having 

national significance, while others with a large concentration of the public (for example, 

major sporting events or skyscrapers) or critical infrastructure facilities. Currently, the U.S. 

has over 500 chemical facilities operating near large populations. U.S. waterways also 

transport over 100,000 annual shipments of hazardous marine cargo, including LPG, 

ammonia, and other volatile chemicals. Many of these substances pose a similar hazard to 

that of LNG. 

• Risk Management - While the risks associated with the transportation of any hazardous cargo 

can never be entirely eliminated, they can be managed. For potential targets where the threat 

is perceived to be high, resources can be directed to mitigate possible attack paths. Such 

efforts may deter potential attacks on one target, but shift efforts to those that are less 

protected. As a result, the issue is how to best direct finite resources. 

For the proposed project, it may be possible to apply risk management resources to manage 

realistic threats; however, an even greater level of resources may be required to manage the threats as 

perceived at the local level. The issue for the decision makers is whether the resources required to 

manage the risks are justified by the benefits, while recognizing that the risks cannot be entirely 

eliminated. 

4.13 CUMULATIVE IMPACTS 

Cumulative impacts may result when the environmental effects associated with a proposed 

project are superimposed on, or added to, either temporary (construction related) or permanent (operation 

related) impacts associated with past, present, or reasonably foreseeable future projects. Although the 

individual impact of each separate project may be minor, the additive or synergistic effects of multiple 

projects would be significant. The proposed Casotte Landing LNG terminal and pipeline interconnects 

would be constructed on Bayou Casotte in Jackson County, Mississippi. The environmental effects of 

construction and operation of the proposed Project are described in Sections 4.1 through 4.11 of this EIS. 

However, we are aware of other major projects that are being proposed for construction in the immediate 

vicinity of Bayou Casotte and Jackson County. This section describes the estimated impact associated 

with each of these projects and the cumulative impact if all projects were constructed. 

The impact from Hurricane Katrina would also lead to several rebuilding and restoration projects 

in the Pascagoula and Jackson County area. These projects consist primarily of home and business 

construction on sites that were previously developed. The COE, through Task Force Hope has been 

responsible for restoring levees and floodwalls, debris removal, and emergency response in the area since 

Hurricane Katrina (COE 2006). Additionally, the COE is also conducting restoration activities along the 

Gulf Coast as a result of the hurricane. These projects have already begun and would be expected to 

continue into the unknown future. These projects were not considered in our cumulative impact 

assessment. More distant projects are not assessed because their impacts would be localized elsewhere 

and would not contribute significantly to impacts in the immediate Project area. 

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Chevron is planning to expand its Pascagoula Refinery to raise output of gasoline by 

approximately 500,000 gallons per day, a 25 percent increase. This increase in output would result from 

an upgrade of the Refinery’s Fluid Catalytic Cracking Unit (FCCU) which currently processes 

65,000 barrels of crude each day. The upgrade of the FCCU would also require other process equipment 

within the Refinery to either be replaced or upgraded, as well. This $150 million expansion project was 

scheduled to begin in July 2005 and be completed in late 2006. However, in the aftermath of Hurricane 

Katrina, the completion date has been delayed. At the peak of project construction in 2006, some 

1,000 contractors are expected to be employed on the project (MDEQ 2005). 

As described in Section 3.3.1.2, Gulf LNG Energy also has proposed an LNG import terminal, 

which would be constructed south of the proposed Casotte Landing Project at the mouth of Bayou 

Casotte. Should it be approved, the timing of the Gulf LNG Energy Project, as currently proposed, would 

be similar to the Casotte Landing Project. 

Aside from the Pascagoula Refinery expansion and the Casotte Landing LNG and LNG Clean 

Energy Projects, no significant commercial or industrial developments associated with shipping and 

related port activities are planned in the Port of Pascagoula area (McAndrews 2005). The closest 

foreseeable development to the west would be casino projects approximately 20 miles away. Land use 

between the Port of Pascagoula and the casinos is primarily residential and would be unlikely to include 

any industrial or major commercial development. The impacts associated with the casino development 

are primarily related to population growth and would extend only as far eastward as the Ocean Springs 

area (COE 2005). Because of the area and types of impacts associated with the casinos, they were not 

considered as part of the cumulative impacts associated with the Casotte Landing LNG Project. The 

Grand Bay Preserve extends along the coast to the east from the Destin and Gulfstream pipeline rights-ofway to beyond the Mississippi State Line. The designation of this area for preservation would preclude 

any development in the foreseeable future. More geographically distant projects were not assessed 

because their impact would generally be localized and therefore, would not contribute significantly to 

cumulative impacts in the proposed project area. 

In addition to development projects, dredging activities may have a cumulative or additive impact 

on some of the same resources affected by the Casotte Landing Project, particularly soils, sediments, 

surface water, and aquatic resources. Aside from the dredging associated with the proposed LNG import 

terminal projects, the primary dredging expected to take place in the project area within the foreseeable 

future would be maintenance dredging of the ship channels and turning basins. 

Table 4.13-1 summarizes the present or reasonably foreseeable future projects or activities that 

may have a cumulative or additive impact on resources that would be affected by construction and 

operation of the Casotte Landing LNG Project. Although it is reasonable to expect that over the next 

25 years various industrial, commercial, recreational, or residential developments would occur in the 

Pascagoula area, without specific proposals to evaluate, the impacts of these developments are not 

reasonably foreseeable. Therefore, these unplanned projects cannot be included in this EIS. 

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TABLE 4.13-1 

Existing or Proposed Activities Cumulatively Affecting Resources of Concern 

for the Casotte Landing Project 

Activity/Project Description Timeframe 

Past and Present Activities/Projects 

Channel and 

Harbor Dredging 

Maintenance dredging of the Pascagoula and Bayou Casotte Channels and 

the Inner Harbor. 

Ongoing 

Pascagoula 

Refinery Expansion 

Expand refinery’s gasoline production capacity by 500,000 gallons per day. Through late 

2006 a

Future Activities/Projects 

LNG Clean Energy 

Project 

LNG import terminal, and associated natural gas pipeline interconnects. 2006-2009 

Channel and 

Harbor 

Maintenance 

Dredging 

Maintenance dredging of the Pascagoula and Bayou Casotte Channels and 

the Inner Harbor. 

Ongoing 

__________ 

NOTES: 

a The completion date for the Pascagoula Refinery may be delayed due to impacts caused by Hurricane Katrina. 

4.13.1 Geology 

Because no significant paleontological or mineral resources have been identified in the Project 

area, the proposed projects would not have a cumulative impact on geological resources. Shoreline 

erosion is a concern along the Mississippi Coast. In general, shoreline erosion can be caused by ship 

traffic or by engineered structures, such as levees along beaches or rivers, up to hundreds of miles away 

from where the erosion problems occur. Natural processes such as tide-induced currents, sea level 

changes, wind waves, and hurricanes or other extreme storms also contribute to shoreline erosion. 

Because the proposed LNG terminal site would contain an angled slip off the Bayou Casotte Channel, the 

LNG marine traffic associated with the Project would not contribute measurably to shoreline erosion 

along the channel or waterway from the territorial seas to the berthing facility. Rock or concrete units 

would be installed on the slope parallel to the shoreline of the ship berth area to protect it from erosion. 

The Pascagoula Refinery expansion will not affect shoreline erosion because it will not disturb 

the coastline. The proposed LNG Clean Energy Project would be located along the Bayou Casotte 

Channel just before it enters the harbor, rather that being located within the harbor where the shoreline is 

close to the channel. Therefore, the LNG carrier traffic associated with the Project would not contribute 

measurably to shoreline erosion along the channel. 

4.13.2 Soils and Sediments 

Clearing and grading associated with construction of the proposed LNG terminal projects and the 

Refinery expansion would accelerate the erosion process and, without adequate protection, would result 

in discharge of sediment to adjacent waterbodies and wetlands. Soil loss due to erosion would also 

reduce soil fertility and impair revegetation. The proposed LNG terminal projects would adopt the FERC 

staff’s Plan or develop comparable measures approved by the FERC to establish a baseline for 

minimizing the potential for erosion as a result of water or wind action and to aid in reestablishing 

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vegetation after construction. In addition, a site-specific SWPPP would be required as part of the general 

permit for construction stormwater discharges. The SWPPP would incorporate various BMPs, as well as 

guidance established in documents developed for erosion control and stormwater management in the State 

of Mississippi. 

None of the land within the proposed Project area is currently under active cultivation, and no 

prime farmland would be permanently converted as a result of the proposed LNG terminal projects. 

Except for the Refinery expansion, the primary activities considered for this cumulative impacts 

analysis involve dredging activities. Estimated dredging volumes and proposed dredge placement sites 

for the projects are provided in Table 4.13.2-1. 

TABLE 4.13.2-1 

Estimated Volumes of Dredged Material for Current and Proposed Projects 

Project 

Estimated Volume 

for Construction 

(million cubic 

yards) 

Proposed Dredged Material 

Placement Site(s) 

Construction of Casotte Landing LNG Project 3.5 ODMDS 

Maintenance Dredging for Casotte Landing LNG 

Project over 20 years 

up to 5.0 ODMDS 

Construction of LNG Clean Energy Project 2.96 ODMDS 

Maintenance Dredging for LNG Clean Energy 

Project over 20 years 

up to 1.2 BCDMMS 

Maintenance Dredging of Bayou Casotte Inner 

Harbor and Turning Basin over 20 years 

3.46 BCDMMS 

Maintenance Dredging of Bayou Casotte Channel 

over 20 years 

undetermined BCDMMS 

Maintenance Dredging of Bayou Casotte Harbor 

Public Ship Berths over 20 years 

0.30 BCDMMS 

Maintenance Dredging of Existing Bayou Casotte 

Harbor Private Industry Ship Berths over 20 years 

0.27 Private placement sites 

Maintenance Dredging of Pascagoula Channel 

and Turning Basin over 20 years 

undetermined undetermined 

___________ 

NOTES: 

ODMDS Pascagoula Ocean Dredged Material Disposal Site 

BCDMMS Bayou Casotte Dredged Material Management Site

Construction and maintenance dredged material associated with the proposed Casotte Landing 

LNG Project is proposed to be placed in the Pascagoula ODMDS. Beneficial use sites have also been 

investigated as a possible dredged material disposal option, which would be an environmental benefit to 

the project area. However, at this time no beneficial use sites are available for use by Bayou Casotte 

Energy. All of the dredged material derived from construction of the proposed LNG Clean Energy 

Project is proposed for placement in the ODMDS. This material would not have a significant effect on 

the capacity of the ODMDS. 

The ship berth and maneuvering area associated with the LNG Clean Energy Project would be 

owned by the Jackson County Port Authority after it is constructed and the Port Authority would be 

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responsible for the maintenance dredging. The material associated with maintenance dredging at the 

proposed facility is proposed to be placed at the BCDMMS. Gulf LNG calculated that the additional 

material associated with maintenance dredging for the LNG Clean Energy Project would reduce the life 

of the BCDMMS from 50 years to approximately 39 years, assuming the maximum potential shoaling 

rate. 

4.13.3 Water Resources 

Construction of the proposed LNG terminal would involve the dredging of a ship berth. The 

primary impacts of dredging on water quality are increased turbidity and sedimentation, the release of 

nutrient-bound contaminants, and decreased dissolved oxygen. 

Initial dredging activities during construction and maintenance dredging during operation would 

result in increased turbidity and sedimentation that would temporarily decrease water quality. If dredging 

associated with the proposed LNG terminal were to occur concurrently with other dredging projects, the 

reduction in water quality would be exacerbated. However, because the Mississippi Sound and Bayou 

Casotte are naturally turbid, noticeable increases in TSS associated with dredging activities for the 

proposed project would be relatively localized. Dredge modeling for the Proposed Casotte Landing 

Project indicated that dredging would not increase TSS levels above current background levels in Bayou 

Casotte. As a result, even if other dredging occurs concurrently, the regions affected by elevated turbidity 

would not likely overlap and additive affects would not be expected to occur. In addition, if the dredging 

projects were undertaken concurrently, the time period of increased turbidity would be shortened. In any 

case, the negative effects of dredging in this substrate would be temporary and water quality would be 

expected to return to ambient conditions after completion of these activities. No long-term cumulative 

impacts on water quality, either in the marine terminal area or along the LNG vessel transit route, would 

result from the dredging activities. 

Propeller wash from LNG marine traffic, oil tankers, and tugboats associated with the LNG 

terminals and Chevron’s Pascagoula Refinery expansion could temporarily increase suspended sediments 

within the waterway. However, given the naturally high turbidity levels within the Mississippi Sound, 

such impacts would not be significant. 

The area comprising both proposed LNG terminal projects was originally used for dredge 

material placement. Aside from the Mississippi Sound and Bayou Casotte, the existing waterbodies 

within the Project area consist of shallow intermittent drainage ditches, dredged canals, and retention 

ponds. The quality of these waterbodies is generally low because of their artificial origin and use for 

industrial stormwater conveyance. The pipeline interconnects for the proposed Casotte Landing Project 

would traverse canals and ditches using the open cut method. The construction of the proposed natural 

gas sendout pipeline associated with the proposed LNG Clean Energy Project would also require the 

crossing of two manmade canals. One canal would be crossed by the horizontal directional drill (HDD) 

construction method and the other would be crossed using the open cut method. Impacts on the canals 

would be minor and short term. 

Runoff from construction activities near waterbodies would also result in cumulative impacts, 

although this effect would be relatively minor and would be controlled during each project by 

implementation of erosion and sediment control measures and by compliance with federal, state, and local 

requirements. Because the potential impacts on waterbodies would be limited to the period of 

construction, and each project would be required to implement erosion and sediment control measures to 

reduce impacts, the collective effects on surface water resources are expected to be minor. 

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4.13.4 Vegetation and Wetlands 

4.13.4.1 Vegetation 

The proposed Casotte Landing Project site is a previously developed industrial area and the few 

existing plants are fast-growing, hardy pioneer species. About 115 acres of upland scrub-shrub habitat 

and 119.3 acres of wetlands (scrub-shrub and emergent) would be affected at the proposed terminal site. 

The proposed interconnect and NGL pipeline routes would affect about 27.6 acres of wetlands consisting 

of scrub-shrub, emergent and forested. Because the Casotte Landing pipeline interconnects would be 

collocated to the extent possible with existing structures, permanent impacts on vegetation would be 

minor. 

Construction of the proposed LNG Clean Energy terminal facilities would permanently remove 

about 43 acres of vegetation communities consisting of scrub-shrub uplands, intertidal mudflats, and 

coastal brackish marsh. Construction of the proposed pipeline and associated aboveground facilities 

would disturb 67 acres of upland vegetation and 16 acres of wetland vegetation. Operation of the 

proposed pipeline facilities would require that about 26 acres of vegetation be converted to permanently 

maintained pipeline right-of-way (25 acres) and aboveground facilities (1.2 acres). 

Although implementation of the proposed LNG terminal projects would permanently remove 

native vegetation, these impacts are not expected to be significant on a regional scale because areas with 

similar vegetation characteristics are found on surrounding lands. Because the Refinery expansion would 

be within the existing, previously disturbed portion of the refinery, no significant impacts on vegetation 

are anticipated. 

The only potential impacts on vegetation along the LNG ship transit route would occur if LNG 

were released from an LNG ship near Petit Bois and Horn Islands. The resulting vapor could burn and 

affect seagrass beds and beach dune vegetation along the western edge of Petit Bois Island and the eastern 

edge of Horn Island. Because these effects would be short-term and fairly limited in area, there would be 

no significant long-term cumulative impacts on vegetation along the transit waterway. 

4.13.4.2 Wetlands 

There would be a permanent loss of some existing wetlands as a result of constructing and 

operating the proposed LNG terminal projects. However, the projects would require, by the terms and 

conditions of their respective CWA permits, compensatory mitigation for wetland damage or destruction. 

Therefore, creation of new wetlands, as required by the CWA, is anticipated to result in a net increase in 

the regional coastal marsh resource. Table 4.13.4-1 summarizes the acres of wetlands impacted by the 

proposed projects. 

TABLE 4.13.4-1 

Wetland Impacts Associated with the Proposed LNG Terminal Projects (acres) 

LNG Terminal Facilities a Pipeline/Interconnects Total Impacts 

Project Temporary Permanent Temporary Permanent Temporary Permanent 

Casotte Landing LNG 

Project 119.3 119.3 15.3 7.9 134.6 127.2 

LNG Clean Energy 

Project 5.8 4.9 14.1 2.6 20.0 7.4 

__________ 

a

 Impacts associated with any nonjurisdictional facilities are not included. 

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As discussed in Section 4.4.3, none of the wetland impacts associated with proposed Casotte 

Landing pipeline interconnects would be permanent and only a small fraction of the wetland impacts 

associated with construction of Gulf LNG’s natural gas sendout pipeline would be permanent. Neither 

waterbodies nor wetlands would be affected by Chevron’s refinery expansion because the expansion 

would occur within the established limits of the existing refinery. 

4.13.5 Wildlife and Aquatic Resources 

4.13.5.1 Wildlife 

Because Bayou Casotte Energy’s proposed LNG terminal would be located on a former industrial 

site adjacent to a refinery, the existing wildlife habitat at the site is not of high quality and only minor 

impacts on wildlife are anticipated. Compensatory replacement of wetland habitat would be required. No 

natural fresh waterbodies would be affected by the proposed Project, rather all of the waterbodies located 

within the footprint of the proposed terminal site are constructed canals, ditches, or ponds that offer 

minimal habitat for aquatic species. 

Habitat within the footprint of the proposed LNG Clean Energy Project terminal would be 

permanently lost to wildlife. Some smaller, less mobile wildlife, such as small mammals, amphibians and 

reptiles, would likely experience direct mortality during clearing and grading activities. Other wildlife, 

such as birds and larger mammals, would likely leave the immediate construction area when construction 

activities approach, perhaps relocating to the Grand Bay Preserve, which would provide similar and 

ample habitat to the east of the proposed project area. Gulf LNG would mitigate for the permanent loss of 

coastal brackish marsh associated with the LNG terminal facilities through compensatory replacement of 

habitat. 

The proposed Casotte Landing Project may encompass habitat for or involve interaction with the 

following federally-listed species: sperm whale, blue whale, sea whale, fin whale, humpback whale, 

North Atlantic right whale, Florida manatee, Gulf sturgeon, green sea turtle, hawksbill sea turtle, Kemp’s 

ridley sea turtle, leatherback sea turtle, loggerhead turtle, bald eagle and brown pelican. However, 

suitable habitat was not identified for federal or state protected species on the proposed LNG terminal 

site. 

Compensatory replacement of wetland habitat would be required. Because ample similar upland 

habitat is available in the area and wetland habitat would be compensated, no adverse cumulative impacts 

on wildlife would be associated with the proposed LNG terminals. 

Most of the pipeline construction areas associated with the proposed LNG terminal projects 

would revert to preconstruction conditions, and therefore, impacts on most wildlife habitat would be 

temporary and short term. Because the majority of the pipeline routes for both LNG terminal projects is 

currently maintained right-of-way or other industrial areas, the cumulative impacts on wildlife and 

wildlife habitat in the area would likely be negligible. Since the Refinery expansion would be within the 

existing, previously disturbed portion of the refinery, no significant impacts on wildlife are anticipated. 

None of the projects considered for this cumulative impacts analysis is anticipated to affect 

wildlife habitats along the LNG ship transit route. No significant cumulative impacts on wildlife along 

the transit route would be expected. 

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4.13.5.2 Aquatic Resources 

The ship berth for the proposed Casotte Landing Project would be constructed in an upland area 

and existing aquatic habitat would not be affected. Maintenance dredging in the Bayou Casotte Channel 

would be within existing dredged areas that have already been disturbed. The Pascagoula Refinery 

expansion would not affect aquatic resources. Dredging of the ship berth and maneuvering area for the 

proposed LNG Clean Energy Project would result in the permanent conversion of 61.3 acres of shallow, 

primarily sandy softbottom habitats to deeper, silty-sand softbottom habitats. Many of the aquatic species 

that currently inhabit shallow water habitat in the project area also inhabit the deeper water of the adjacent 

Bayou Casotte Channel. These species are not likely to be negatively affected by the alteration in habitat. 

Aquatic species that prefer the shallow water habitat would experience a loss of habitat due to dredging; 

however, the large amount of similar habitat in the vicinity of the project area would provide ample 

habitat for individuals displaced by construction activities 

As discussed in Section 4.13.3, construction dredging for the proposed Casotte Landing LNG 

Project and the LNG Clean Energy Project and maintenance dredging for the two LNG terminal projects 

and the Port of Pascagoula would result in temporary increases in turbidity, which would have impacts on 

aquatic resources. These impacts would be mostly temporary and localized, and mitigation measures 

would be required to reduce turbidity. Because the dredging activities for the projects would be unlikely 

to occur at the same time and in close proximity, they would not cause cumulative impacts on aquatic 

resources. 

LNG ships and crude oil tankers would take on water during offloading for ballast and for engine 

cooling while they are at the berth at the proposed LNG terminals and the Chevron Pascagoula Refinery. 

Water used for engine cooling would be quickly discharged, and the resulting increase in water 

temperature is expected to be minor. Intake of water could also result in the entrainment of aquatic 

resources. The majority of species identified by the NOAA Fisheries occur in low densities in the project 

area. In contrast, blue crab and penaeid shrimp occur in high densities in the project area; however, they 

exhibit naturally high mortality rates. These combined effects account for the negligible impact to these 

species. The resulting low numbers removed from these species populations would be expected to have a 

minimal impact on the ecology in the project area and the surrounding Mississippi Sound, including food 

chain relationships. 

Several federally-listed threatened or endangered aquatic species, including whales, sea turtles 

and Gulf sturgeon are potentially present in the area affected by the proposed LNG terminal projects and 

the maintenance dredging activities, including the LNG ship transit route. The proposed Casotte Landing 

project would affect 6.3 acres of Gulf sturgeon critical habitat and the proposed LNG Clean Energy 

Project marine facilities would be within Gulf sturgeon critical habitat and the ship channels servicing the 

Port of Pascagoula also pass through this critical habitat. To minimize impacts on Gulf sturgeon and its 

critical habitat, Bayou Casotte Energy would implement agency dredging requirements, concurrent 

scheduling of future maintenance dredging, and its SPCC Plans. In addition, Gulf LNG has agreed to 

perform a 3-year post-construction prey and habitat assessment survey of the ship berth and maneuvering 

area and adjacent areas. With the implementation of the above measures, we have determined that the 

Gulf sturgeon and its designated critical habitat would not likely be adversely affected by construction 

and operation of the Casotte Landing LNG Project. The other listed aquatic species also would not likely 

be adversely affected by the proposed projects. 

Both of the proposed LNG projects would implement the Strike Avoidance Procedures to 

minimize potential impacts from LNG marine traffic on whales and sea turtles. For these reasons, we 

anticipate minimal adverse cumulative impacts on special status aquatic species. 

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Impacts on EFH from construction of the proposed Casotte Landing Project include disturbance 

of 6.3 acres of unvegetated benthic habitat needed to connect the proposed marine slip to the ship 

channel. However, the permanent creation of 26 acres of similar unvegetated benthic habitat in the 

marine slip area would likely offset this temporary disturbance. The proposed LNG Clean Energy Project 

would also have an impact on habitat types that function as EFH. Species with EFH designated in the 

Mississippi Sound would potentially be impacted by loss/alteration of habitat, dredging, permanent loss 

of 9 acres of intertidal wetland, entrainment of benthic invertebrates, and the temporary resuspension of 

sediments into the water column during construction. Although there would be permanent impacts on 

EFH as the result of project construction, Gulf LNG’s proposed mitigation, in combination with 

mitigation for intertidal wetland losses, would compensate for these impacts through the creation of 

habitats. Maintenance dredging activities would cause a temporary increase in turbidity, but not 

significantly above background levels and mitigation measures would be implemented to reduce turbidity. 

With mitigation, we do not believe cumulative impacts on EFH associated with construction or operation 

of these projects would have a substantial adverse effect on managed fisheries in the area. 

4.13.6 Land Use, Recreation, and Visual Resources 

4.13.6.1 Land Use 

The proposed project and the other foreseeable future projects would result in minor changes to 

current land uses. The proposed Casotte Landing Project would be constructed on a former 

manufacturing site adjacent to the Chevron Pascagoula Refinery. The Pascagoula Refinery expansion 

would take place within the existing refinery property and would not involve land use changes. The land 

use surrounding these projects consists primarily of industrial properties. Gulf LNG’s terminal would be 

constructed on a tract of land located in an area that was previously used for dredged material placement, 

has no current structures or access, and is designated for water-dependent industrial use. The conversion 

of the site from an undeveloped, open area to an industrial use would be consistent with its designated 

use, as well as with other industrial facilities in the area. There is no agricultural or residential land in the 

vicinity that would be affected by the projects. No residential or other developed land is present along the 

LNG ship transit route. Material generated during maintenance dredging for the port would be placed in 

approved, previously used placement areas. 

4.13.6.2 Recreation 

Recreational fishing and boating occur in Bayou Casotte and Mississippi Sound, although 

existing recreational boating and fishing use in the immediate vicinity of the proposed project is limited. 

The construction of the marine berth for the proposed Casotte Landing Project would be within an 

existing upland area and would have minimal impacts on recreational boating and fishing. The relatively 

shallow water depths in the vicinity of the proposed LNG Clean Energy Project (ranging from 0 to 8 feet 

but generally less than 4 feet deep) preclude many recreational boaters from utilizing this area. The 

proposed projects would potentially negatively affect recreation, primarily during the period of active 

construction and dredging. However, recreational boating and fishing activities are not expected to be 

significantly affected during construction of the marine facilities because of the nature of the work site 

(i.e., shallow water) and the fact that recreational boaters who do currently operate in the area are 

accustomed to avoiding existing vessel movements similar to those that would be experienced during 

construction of the project. Operation of the proposed Casotte Landing Project would affect recreational 

boating and fishing in the Bayou Casotte during the arrival, unloading, and departure of LNG marine 

traffic. Bayou Casotte Energy anticipates 170 LNG ship visits per year. While in transit or docked, LNG 

vessels would have a security zone enforced around them. Other vessels, including recreational boats, 

would be prohibited within the security zone during the arrival of LNG marine traffic. These effects 

would be temporary while the boat is in transit or moored at the ship unloading facility. The maximum 

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delay expected due to the transit of an LNG vessel would be 1.5 hours. The security zone typically would 

extend 2 miles ahead and 1 mile behind the ship during transit. The extent of the security zone around the 

LNG carrier while it is unloading would be established by the Coast Guard but is not expected to interfere 

with traffic along the adjacent Bayou Casotte Channel. 

Operation of the LNG Clean Energy Project would affect recreational boating and fishing in the 

Mississippi Sound during the arrival, unloading, and departure of LNG marine traffic. Gulf LNG 

anticipates that approximately 150 ships would unload at the LNG terminal each year. Docks in the Port 

of Pascagoula currently accommodate commercial ships. As a result, marine traffic associated with the 

project would not introduce any significant new type of impacts on recreational boating or fishing. 

Security zone restrictions similar to those applied to Casotte Landing would apply. 

The potential increase of up to 320 LNG ships per year from the two proposed LNG terminal 

projects would have a minimal affect on recreational activities in the area; however, neither of these 

projects is located in an area of high recreation usage. Recreational vessels that are not constrained to the 

dredged channel would not be adversely affected by the additional shipping traffic because these smaller 

vessels can operate outside the confines of the channel and remain clear of the LNG marine traffic. In 

addition, the LNG terminal projects are located on lands dedicated to industrial uses and are not near 

recreation areas. 

Maintenance dredging for the LNG terminal projects or for other port activities would not have 

cumulative impacts on recreational boating or fishing because the disturbance associated with a given 

area would be localized and temporary in nature. 

4.13.6.3 Visual Resources 

The visual characteristics of the existing landscape are defined by historic and current land uses 

such as agriculture, recreation, conservation, and development. The visual qualities of the landscape are 

further influenced by existing linear installations such as highways, railroads, pipelines, and electrical 

transmission lines, and by the industrial facilities located along the Bayou Casotte Harbor. Within this 

context, the LNG storage tanks at the proposed LNG terminals would have the most impact on visual 

resources in the area. The pipeline portions of the proposed LNG terminal projects would be visually 

subordinate to the existing landscape character and would contribute only incrementally to overall visual 

conditions, particularly because the pipeline routes would primarily be within existing rights-of-way. The 

LNG terminal facilities would be located in an area with several existing industrial facilities, which would 

lessen their visual impact because their presence would be generally consistent with the current viewshed 

in the area. Likewise the refinery expansion would be within the limits of the existing refinery. 

Maintenance dredging activities would not have an impact on visual resources. The LNG ships and oil 

tankers would be operating within established federal navigation channels used by other commercial 

vessels. Therefore, the proposed projects would not significantly contribute to cumulative effects on 

visual resources. 

4.13.7 Socioeconomics 

With the exception of the maintenance dredging activities, present and reasonably foreseeable 

future projects and activities would have a cumulative impact on socioeconomic conditions in the project 

area. Employment, housing, infrastructure, and public services would experience both beneficial and 

detrimental impacts. Based on letters of support that the proposed project has received from state and 

local officials (i.e., Mayor of the City of Pascagoula, President of the Jackson County Port Authority, 

Governor of the State of Mississippi) the Pascagoula area has a need for projects such as the proposed 

LNG terminals to aid in its economic recovery after Hurricane Katrina. Therefore, the present and 

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reasonably foreseeable future projects and activities considered for this analysis are likely to have a 

positive net socioeconomic impact. None of the projects appear to have environmental justice issues, 

given the industrial nature of the sites (i.e., away from residential areas). 

4.13.7.1 Economy and Employment 

The projects considered in this section would have cumulative effects on employment during 

construction if construction schedules overlap. During construction, the proposed Casotte Landing 

Project would employ 50 to 100 workers during non-peak construction periods with 400 to 600 workers 

during peak periods, which would occur about 50 percent of the time. The proposed LNG Clean Energy 

Project would employ an average workforce of 259, with a peak workforce of 556 at the beginning of the 

third year of construction. Bayou Casotte Energy estimates that 30 percent of the workforce would be 

local and Gulf LNG estimates that 64 percent of the workforce would be local. Currently, the proposed 

schedules for the two proposed LNG terminal projects are similar. 

The Pascagoula Refinery expansion is expected to employ 1,000 workers at the peak of 

construction. Based on the original schedule before Hurricane Katrina, the refinery expansion would 

have been entirely or largely completed before construction of the proposed LNG terminal projects began. 

The hurricane delayed the construction schedule, possibly resulting in more overlap between the project 

schedules. In this event, more non-local workers may need to be hired temporarily. However, the 

impacts of this relatively small number of workers temporarily relocating to the area would be minor. 

As discussed in Section 4.8.2, the Hurricane Katrina reconstruction effort and the specialized 

construction requirements of the proposed LNG terminal projects are expected to draw from different 

sectors of the construction workforce. Therefore, construction employment for the proposed LNG 

terminal projects should not conflict with hurricane reconstruction efforts. 

While most of the jobs created by the proposed LNG terminal projects and the refinery expansion 

are temporary construction jobs, permanent employment would also increase in the project area. The 

LNG terminal projects would each employ 50 permanent workers. The refinery currently employs about 

300 permanent workers. 

In addition to impacts on local employment, these projects would provide an increase in revenue 

for the State of Mississippi, Jackson County, and the local economies through the payment of payroll tax, 

sales tax, property tax, and other taxes and fees. During operation, The proposed Casotte Landing Project 

would have an annual payroll of about $3,000,000 and would pay $13,606,000 annually in taxes and fees 

to the county. Payroll for the LNG Clean Energy Project would be $4,000,000 annually; and annual ad 

valorem taxes, lease fees, and port fees are anticipated to be $14,809,000. Cumulatively, these projects 

would have a beneficial impact on Jackson County and local economies and governments. 

4.13.7.2 Housing 

Temporary housing for the construction workers would be needed for the portion of the 

workforce not drawn from the local area. During the two years of peak construction activity, 180 units 

would be required to house temporary construction workers. If the LNG Clean Energy Project were 

under construction at the same time, the demand would be as much as double that amount. 

Although Hurricane Katrina has caused a temporary shortage in supply of temporary housing, 

area motels are expected to be fully operational in 2006. The peak construction period for the proposed 

Casotte Landing Project is expected to occur in 2008 when additional temporary housing facilities would 

be available if required by project personnel. If adequate temporary housing is not available in 

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Pascagoula or the immediate surrounding area, some workers may be required to commute from areas 

further away. 

4.13.7.3 Infrastructure and Services 

Infrastructure and services may be affected when population increases if existing infrastructure 

lacks spare capacity. The small incremental demands of several construction projects occurring at the 

same time would place extra demands on police, fire, and emergency service personnel. However, this 

problem would be temporary, and would be somewhat offset by addressing additional service staff and 

shifts. In addition, cumulative impacts to disposal and waste management services would also be 

minimal, as sufficient space is available in the landfills near the project area and given that the majority of 

waste generated at the construction site would be Class 3 industrial waste. 

The permanent impact of the proposed Casotte Landing Project on the emergency response 

services (i.e., police, fire, and medical) is discussed in Section 4.12. Both of the proposed LNG terminal 

projects would be required to develop an Emergency Response Plan in coordination with local emergency 

service providers and municipal, county, and local specialized units located within other nearby 

industries. These plans are anticipated to be developed in conjunction with one another. Furthermore, the 

plan for the proposed Casotte Landing Project would likely be coordinated with the existing Pascagoula 

Refinery emergency response plans due to the close relationship (i.e., proximal and operational) between 

the two facilities. 

4.13.8 Transportation 

4.13.8.1 Marine Transportation 

The current volume of ship traffic for the Port of Pascagoula, as a whole, is an average of about 

three one-way transits per day. The average number of ship transits per day for Bayou Casotte Harbor is 

two, most of which are oil tankers calling at the Pascagoula Refinery. 

The two proposed LNG terminals and the Pascagoula Refinery expansion would result in an 

increase in ship traffic in the port. The combined number of LNG ships for the two facilities would be 

about 320 vessels. Based on an increased output of about 500,000 gallons of gasoline per day at the 

refinery, and assuming 2.1 gallons of crude oil per gallon of refined gasoline (Energy Information 

Administration, 2004) and an oil tanker capacity of 22 million gallons, 17 additional oil tankers would 

visit the refinery. For all three projects, the annual increase would be 337 vessels (see Table 4.13.8-1), or 

approximately two one-way transits per day. Each transit would take approximately 2 hours and multiple 

inbound or outbound ships would use different portions of the Port of Pascagoula channels at the same 

time. The realistic maximum delay that one ship transiting the channels would pose on another ship 

transiting the GIWW is roughly 30 minutes. If two ships were traveling one right after another along the 

Port of Pascagoula channels (an unlikely scenario), the maximum delay for a ship transiting the GIWW 

would be 1 hour. 

Small vessel traffic (e.g., commercial fishing vessels and recreational vessels that are not 

constrained to the dredged channel) would not be adversely affected by the additional shipping traffic 

because these smaller vessels can operate outside the confines of the channel and remain clear of the LNG 

marine traffic. 

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TABLE 4.13.8-1 

Estimated Number of Ship Calls for the Proposed LNG Terminal Projects 

and the Refinery Expansion Project 

Project 

Estimated Number of Ship Calls 

per Year 

Casotte Landing LNG Project 170 

LNG Clean Energy Project 150 

Pascagoula Refinery Expansion 17 

Total 337 

In most ports, the greatest constraint on traffic management is the availability of tugs. The 

Pascagoula Pilots consider the current tug fleet operating in the port to be adequate for current operations; 

however, additional tugs would likely be required to accommodate the proposed LNG projects. Bayou 

Casotte Energy and Gulf LNG would provide needed information for ship-assist tug companies to 

determine the requirement for adequate tugs, with sufficient power rating, to meet the needs of the LNG 

terminals. The Pascagoula Pilots have also indicated that they would need to add at least two pilots to 

their workforce to accommodate the increased ship traffic associated with operation of the proposed LNG 

terminals. Although it takes up to 1 year to become a fully qualified and licensed Pascagoula Pilot, the 

timeframe involved in permitting and constructing of the LNG terminals would provide ample 

opportunity to make the necessary workforce adjustments. Overall, the cumulative increase in ship traffic 

would have minimal impacts on port and waterway operations. 

In addition to the Pascagoula Pilots, the Coast Guard would control the transit of the LNG carrier 

through the harbor and while unloading LNG. Typical Coast Guard requirements for other LNG import 

terminals include 96- and 24-hour advance notification of the LNG carrier arrival. Upon arrival at the sea 

buoy, Coast Guard personnel may board the LNG carrier for an inspection of the ship safety systems and 

review of the manifest. Other requirements may include: a Coast Guard escort through the channel and to 

the dock; establishment of a moving safety and/or security zone around the LNG carrier while in transit 

and during unloading operations; an inspection of the dock safety systems prior to commencing LNG 

transfer; monitoring of all operations until the LNG carrier departs; and maintaining security of the dock 

and LNG carrier. 

4.13.8.2 Land Transportation 

Bayou Casotte Energy has not quantitatively assessed the impacts of construction of the proposed 

Casotte Landing Project on traffic; however, given its similar location and nature, we assume the impacts 

would be comparable to the impacts associated with the proposed LNG Clean Energy Project. Given the 

similar schedules, the two projects combined would increase traffic on State Highway 611 by 27 to 

35 percent. Bayou Casotte Energy proposes to schedule deliveries to the site during off-peak hours to 

avoid congestion as well as have construction personnel arrive and leave during off-peak times for 

commuters. Bayou Casotte Energy has also proposed to have the majority of its deliveries made via 

marine transport. Gulf LNG has proposed similar mitigation (workers would be ferried from off-site 

parking to the project site via tugs and other small boats) as well as staggering shift startup to minimize 

traffic congestion and reduce potential cumulative impacts to a level that is not significant. 

At the peak of construction associated with the Pascagoula Refinery expansion construction, 

about 1,000 workers would be employed, resulting in about 2,000 individual vehicle trips per day. 

Although the completion of the refinery expansion may be delayed due to Hurricane Katrina, the majority 

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of the work is likely to be completed before either of the proposed LNG terminal projects would begin. 

Therefore, any construction period overlap for all three projects would be brief and the peak workforce 

would not be present for any of the projects. 

Operation of the proposed LNG terminals would each require an estimated 50 employees. The 

additional traffic generated by these employees on a daily basis would not result in a significant increase 

in local traffic volume, and would not adversely affect traffic on area roadways. Likewise, the number of 

employees associated with operation of the expanded Pascagoula Refinery is not likely to generate a 

significant volume of additional traffic. In addition, the varied work schedules of the employees would 

reduce any potential for additional traffic congestion. 

It is unlikely that each project would reach peak traffic conditions simultaneously. Also, because 

construction workers frequently share rides and travel to and from work during off-peak hours, potential 

cumulative impacts on traffic from pipeline construction are expected to be temporary and short term. 

Once pipeline construction is complete, there would be negligible impacts on traffic during operation and 

maintenance of the facilities. 

4.13.9 Air Quality and Noise 

Construction of the proposed project and the reasonably foreseeable projects and activities listed 

in Table 4.13.9-1 would involve the use of heavy equipment that produces noise, air contaminants, and 

dust. Operation of the proposed Project (including the LNG terminal and ships delivering LNG to the 

terminal) and the reasonably foreseeable projects would also contribute cumulatively to ongoing air 

emissions and noise. 

Table 4.13.9-1 lists the air emissions associated with construction and operation of the two 

proposed LNG terminal projects and the Pascagoula Refinery expansion in relationship to existing air 

emissions in Jackson County. Although the region is currently in attainment with air quality standards, 

increases in point industrial sources would have a deleterious effect on local and regional air quality. If 

all of the proposed projects are built, there would be slight increases in CO, SO2, VOC, and NOx

emissions during construction and operation and PM10 during construction. Each of the individual 

projects would be required to obtain an air quality permit from the MDEQ, which may specify controls to 

limit the emission of certain criteria pollutants or HAPs. Increases in PM10 during construction would be 

mitigated by BMPs. The permit process would ensure that air emissions from operation of the proposed 

Project and other foreseeable future projects would not cause air quality to deteriorate beyond acceptable 

levels as specified by air quality regulations (see Section 4.11.1.3). 

During operation of the LNG terminals, air emissions from LNG marine traffic and other projectrelated vessels would occur along the entire waterway from the territorial seas to the ship berths. The 

NAAQS do not apply to mobile sources. Because of the transitory nature of these sources and the large 

area covered, these 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 proposed project by its self against Class I and Class II area SILs and the 

NAAQS. The results of the analysis showed predicted concentrations from the project, which included 

stationary sources at the terminal, LNG carrier unloading and hotelling emissions while berthing at the 

terminal, as well as the emissions associated with operation of other marine vessels (i.e., Coast Guard 

boats and tug boats) supporting the facility, to be below the Class I area SILs and below the Class II area 

NAAQS. Since the Class I area impacts were predicted to be below the SILs, the project is not 

considered to be significant and no further Class I area analysis is required. 

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TABLE 4.13.9-1 

Proposed LNG Terminal Projects and the Refinery Expansion Project Emissions Summary 

Air Emissions 

Project CO NOx VOC PM10 SO2

Existing Sources in Jackson County a 68,609 35,596 28,262 12,643 38,190 

 

Construction of Projects (total tons) 

Casotte Landing LNG Project (2006-2009) 2,464.4 488.6 146.4 62.2 39.5 

LNG Clean Energy Project (2006-2009) 436.9 822.6 69.8 2,721.1 124.2 

Pascagoula Refinery Expansion (2006) NA NA NA NA Na 

Total construction (percent of existing sources)b 1.4 1.2 0.3 7.3 0.1 

 

Operation of Projects (tons per year) 

Casotte Landing LNG Project (>2009) c 309.93 493.8 47.4 37.6 118.1 

LNG Clean Energy Project (>2009) c 389.6 670.0 50.9 22.1 605.1 

Pascagoula Refinery Expansion (>2006) 98.2 39.8 31.1 14.6 38.4 

Total operation (percent of existing sources) 1.2 3.4 0.5 0.6 2.0 

____________ 

NOTES: 

a

 Area sources plus point sources; from EPA AIRDATA: http://www.epa.gov/air/data/geosel.html b

 Based on a 3-year construction period for both the Casotte Landing LNG and LNG Clean Energy Projects. c

 Air emissions from mobile and stationary sources. 

CO carbon monoxide 

NOx nitrogen oxides 

VOC volatile organic compound 

PM10 particulate matter less than 10 microns in diameter 

SO2 sulfur dioxide 

NA not available 

In order to provide a more thorough evaluation of the potential impacts on air quality, an 

additional Class I and Class II area modeling analysis was conducted for the Casotte Landing LNG 

Project and LNG Clean Energy Project combined. The results of this analysis were filed with the 

Commission on November 8, 2006 under the Casotte Landing LNG Project. Although further Class I 

area analysis was not necessary, Class I area impacts (including visibility and deposition) were predicted 

from both projects and were found to be below the NAAQS and applicable air quality-related values. 

Because the Casotte Landing Project impacts were expected to exceed several Class II SILs, an additional 

cumulative analysis was conducted. The results of the modeling analysis of the two LNG projects 

combined showed that emissions of PM10, SO2, and NOx would exceed Class II area SILs. However, with 

the background concentrations included, the emissions were predicted to be below the NAAQS. The 

modeled Class II area impacts resulting from both projects are presented in Table 4.13.9-2. 

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TABLE 4.13.9-2 

Summary of Class II Area Impacts Resulting From the Casotte Landing LNG and LNG Clean 

Energy Projects 

Pollutants 

Averaging 

Period 

Highest 

Modeled 

Impact a

(μg/m3) 

Significant 

Impact Level 

(μg/m3

) 

Background 

Value b 

(μg/m3) 

Total Impact 

(including 

background) c (μg/m3

) 

NAAQS 

(μg/m3) 

SO2 3-hour 199.0 25 121 320.0 1,300 

 24-hour 99.0 5 52 151.0 365 

 Annual 4.1 1 8 12.1 80 

CO 1-hour 756.2 2,000 2,290 3,046.2 40,000 

 8-hour 193.9 500 1,947 2,140.9 10,000 

PM10 24-hour 24.5 5 51 87.6 150 

 Annual 1.3 1 20 21.3 50 

NO2 Annual 12.6 1 15 48.1 100 

___________ 

NOTES: 

a

 Highest impacts presented in Table 3-8 of the “Joint Air Dispersion Modeling Analysis for The Casotte Landing Natural 

Gas Import Terminal Project and Gulf LNG Clean Energy Project” dated November 7, 2006. 

b

 Based on background values presented in Table 4.12.1-8. 

c

 Total Impact = Highest Modeled Impact + Background Value. 

μg/m3

 micrograms per cubic meter 

At the time of the above modeling analysis, the appropriate data from the Pascagoula Refinery 

expansion was not available for inclusion. Therefore, to evaluate the impacts of all three projects 

combined for the pollutants that exceeded the Class II area SILs for the LNG Casotte Landing Project 

alone, the modeled results from both the Casotte Landing LNG Project and the LNG Clean Energy 

Project (presented in Table 4.13.9-2) were conservatively scaled up to include the emissions from 

operation of the Pascagoula Refinery expansion (presented in Table 4.13.9-1). Table 4.13.9-3 presents 

the scaled cumulative impacts for comparison to the NAAQS. As shown, the total scaled cumulative 

impacts are well below the NAAQS for all pollutants and averaging times. Based on the modeled results 

and scaled cumulative values, we do not believe there would be a significant cumulative impact on air 

quality. 

Noise sources during construction of the LNG terminal projects and the Pascagoula Refinery 

expansion would create temporary impacts, but they would be localized and would attenuate quickly as 

the distance from the noise source increases. There are no sensitive noise receptors such as residences or 

schools nearby. Therefore, cumulative noise impacts associated with construction of all of the projects 

are not anticipated to be significant. No long-term cumulative noise impacts are anticipated from the 

facilities or associated ships along the waterway during operation. 

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Table 4.13.9-3 

Summary of Class II Area Impacts Resulting From the Casotte Landing LNG and LNG Clean 

Energy Projects 

Pollutants 

Averaging 

Period 

Highest 

Modeled 

Impact a

(μg/m3

) 

Emission 

Rate 

Scaling 

Ratio b

Scaled 

Cumulative 

Impact c 

(μg/m3) 

Background 

Value a

 

(μg/m3

) 

Total 

Scaled 

Cumulative 

Impact d

(μg/m3

) 

NAAQS 

(μg/m3

) 

SO2 3-hour 199.0 209.0 121 330.0 1,300 

 24-hour 99.0 1.05 104.0 52 156.0 365 

 Annual 4.1 4.3 8 12.3 80 

PM10 24-hour 24.5 1.24 30.4 51 81.4 150 

 Annual 1.3 1.6 20 21.6 50 

NO2 Annual 12.6 1.03 13.0 15 28.0 100 

___________ 

NOTES: 

a

 Based on values listed in Table 4.14.8-2. 

b

 Emission ratio estimated by dividing the sum of the operating emissions associated with LNG Clean Energy Project, 

Casotte Landing LNG Project, and the Pascagoula Refinery Expansion by the sum of the operating emissions from the 

Casotte Landing LNG Project and the LNG Clean Energy Project listed in Table 4.14.8-2 for the pollutant of interest. 

c

 Estimated by multiplying the highest modeled impact by the listed emission rate scaling ratio. 

d

 Total scaled cumulative impact = Scaled Cumulative Impact + Background Value. 

μg/m3

 micrograms per cubic meter 

4.13.10 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 LNG terminal facilities 

would be sited, designed, constructed, operated, and maintained in compliance with the federal safety 

standards summarized in Table 2.8.1-1. The pipelines and aboveground facilities associated with the 

proposed LNG Project would be designed, constructed, operated, and maintained in accordance with 

DOT Minimum Federal Safety Standards in Title 49 CFR Part 192. The Coast Guard would assess the 

suitability of the waterway for LNG marine traffic by issuing an LOR. 

Several of the present or reasonably foreseeable future projects, including the proposed Project, 

would involve cargo terminals that would be expected to ship 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. In 

addition, it is difficult to measure the cumulative risk for an intentional attack on the Port or the LNG 

facility. The addition of the LNG facility and its associated LNG marine traffic would not significantly 

change the risk of an intentional attack in the Horn Island, Pascagoula and Bayou Casotte Channels. It is 

reasonable to assume that the rate of ship accidents (including those involving the release of hazardous 

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materials) is likely to rise with more vessel traffic, which would cumulatively increase the risk of an 

accident having an impact on public safety. As discussed in Section 4.13.8, the Pascagoula Pilots manage 

vessel traffic to insure safe transit in the Horn Island, Pascagoula, and Bayou Casotte Channels. The 

Coast Guard would also enforce any moving safety zone and moored vessel security zone around LNG 

marine traffic which may be established. These and other operational controls by the Coast Guard and 

Pascagoula Pilots would minimize the risk of accidents involving LNG marine traffic. 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 

carrier and terminal. 

Emergency response time is a key aspect of public health and safety. No significant cumulative 

impacts on emergency services are expected because sufficient emergency services and facilities exist in 

the area to accommodate the cumulative projects. No significant cumulative impacts on emergency 

services are expected during operation of the proposed Project. Section 4.12.5.5 includes our 

recommendation that Bayou Casotte Energy prepare an 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. Bayou Casotte 

Energy 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. 

4.13.11 Conclusions 

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 cumulative 

impacts we have identified for the proposed Casotte Landing Project would be temporary and minor. 

Consequently, their addition to other reasonably foreseeable impacts in the region does not result in an 

overall permanent increase of impacts. Construction of the two LNG terminal projects, if done more or 

less concurrently, would place pressure on local temporary housing supplies for temporary workers. 

However, these impacts are expected to be minor. The Project would cumulatively contribute to 

increased ship traffic in the Port of Pascagoula and increased air emissions. Although the LNG terminal 

projects would result in the degradation and loss wetlands and other habitats, compensatory mitigation 

programs for each of these projects would be designed to provide a net benefit to the ecosystem. The 

Project would also cumulatively benefit the local economy through job creation and wages, purchases of 

goods and materials, tax revenues, and by providing a new source of competitively priced natural gas. 

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5.0 CONCLUSIONS AND RECOMMENDATIONS 

5.1 SUMMARY OF THE STAFF’S ENVIRONMENTAL ANALYSIS 

The conclusions presented are those of the environmental staff of the FERC. The Coast Guard, in 

its LOR, will address the suitability of the Pascagoula Bar, Horn Island Pass, Lower Pascagoula, and 

Bayou Casotte Channels for LNG marine traffic. Likewise, the COE will present its own conclusions and 

recommendations in the dredging, dredged material placement, and wetland permits it may issue pursuant 

to section 10 of the River and Harbors Act, section 103 of the MPRSA, and section 404 of the CWA. The 

EPA has the authority to review and veto the COE decisions on the section 103 and 404 permits. 

We have determined that construction and operation of the Casotte Landing LNG Terminal 

Project would result in limited adverse environmental impacts. If the proposed Project is found to be in 

the public interest and is constructed and operated in accordance with recommended mitigation measures, 

it would be an environmentally acceptable action. Our conclusion is based on information provided by 

Bayou Casotte Energy and data developed from data requests; field investigations by Commission staff; 

literature research; alternatives analysis; comments from federal, state, and local agencies; and input from 

public groups and individual citizens. 

If the Coast Guard issues a LOR, with conditions, finding the waterway suitable for LNG marine 

traffic, the arrival, transit, cargo transfer, and departure of LNG marine traffic would be required to 

adhere to the procedures of an LNG Vessel Transit Management and Emergency Plan to be developed by 

the Coast Guard Sector Mobile and the Coast Guard District Eight Commander. In addition, Bayou 

Casotte Energy would develop Operations and Emergency Manuals in consultation with the Coast Guard. 

These procedures would be developed to enhance the safety and security of all operations associated with 

LNG ship transit and unloading. 

As part of our review, we developed measures that we believe would appropriately and 

reasonably avoid, minimize, or mitigate for environmental impacts resulting from construction and 

operation of the proposed Project. We are, therefore, recommending that our mitigation measures be 

attached as conditions to any authorization issued by the Commission. 

5.1.1 Geology 

Construction and operation of the Casotte Landing LNG Terminal Project would have minimal 

impact on geological resources. The existing topography at the LNG terminal site would be permanently 

changed by the excavation and dredging of an unloading slip for the marine terminal. The natural 

topographic slope and contours would be temporarily altered along much of the pipeline interconnect 

route by grading and trenching activities. However, Bayou Casotte Energy would restore topographic 

contours and drainage conditions to preconstruction conditions following installation of the pipeline 

interconnects. 

No oil or gas wells are present in the vicinity of the proposed LNG terminal site or pipeline 

interconnect route. Construction of the pipeline interconnects would be limited to near-surface 

disturbance and measures would be taken to avoid and protect individual wells and existing pipelines 

within the proposed pipeline right-of-way. Therefore, the Project would not affect oil and gas production 

in the area. No other known mineral resources or significant paleontological resources are present at the 

proposed LNG terminal site or along the proposed pipeline interconnect route. 

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Potential geologic hazards in the Pascagoula area consist of seismic-related hazards, subsidence, 

flooding, storm surge, and shoreline erosion. Slope instability and inadequate load-bearing capacity of 

soils could also pose a hazard at the proposed LNG terminal. Conditions necessary for the development 

of other geologic hazards, including karst terrain, landslides, avalanches, and volcanism are not present in 

the Project area. The potential for geologic hazards to significantly affect the construction or operation of 

the proposed Project is low. The risk of damage resulting from geologic hazards would be avoided or 

reduced by specific engineering design criteria, ground modification, other construction techniques, and 

operating procedures to be implemented by Bayou Casotte Energy. 

5.1.2 Soils and Sediments 

The majority of the soils impacted by the construction of the proposed Casotte Landing terminal 

site would be poorly drained altered soils consisting primarily of fill material with little to no erosion 

potential. Approximately 28 percent of the soils within the proposed terminal site are hydric in nature. 

About 65 percent of soils found on the LNG terminal site are classified as fill material. About 88 percent 

of the interconnect spur pipeline would cross hydric soils. To mitigate potential impacts on soil resources 

in the Project area, Bayou Casotte Energy would implement its Plan and Procedures, as modified in this 

EIS, during construction and restoration of the LNG terminal site and pipeline interconnect. 

Some soil contamination has also been detected at the proposed LNG terminal site; however, 

remediation activities were conducted at the site in an attempt to remove the contaminated soils from the 

previous industrial operations. No significant exposure risk is anticipated. 

Approximately 1 mcy of soil would be excavated and 3.5 mcy of sediment would be dredged 

during construction of the marine terminal. Because of the angled design of the marine slip, no dredging 

would be required within Bayou Casotte Channel or the turning basin. Some of the excavated material 

would be re-used on site for facility foundations and the hurricane levee. The remainder of the excavated 

material would be disposed of offsite. Bayou Casotte Energy proposes to place sediments dredged from 

the slip into bottom dump scows for disposal at the EPA’s permitted Pascagoula ODMDS located in the 

Gulf of Mexico south of Horn Island. Bayou Casotte Energy has submitted its Section 103 evaluation of 

the MPRSA and filed a DMMP with the COE for approval. Model studies performed by Bayou Casotte 

Energy predicted that total suspended solids resuspended from dredging operations would not be 

significantly different than levels already exhibited in Bayou Casotte Channel. Based on sediment 

sampling conducted by Bayou Casotte Energy, as well as sediment analysis of the Bayou Casotte Channel 

area conducted by the COE for its proposed maintenance dredging, low levels of contaminants exist in the 

sediments but would not be a concern. 

5.1.3 Water Resources 

Construction and operation of the proposed Casotte Landing Project would not have a significant 

impact on groundwater resources in the Project area. There are two public water supply wells located 

within a 1-mile radius of the proposed LNG terminal site. Both wells are located north along Bayou 

Casotte, upstream and up-gradient from the proposed Project and would be unlikely to be impacted by the 

Project. The greatest potential for impact on groundwater would be from spills, leaks, or other releases of 

hazardous substances during construction or operation. To prevent or mitigate these potential impacts,

Bayou Casotte Energy has developed an SPCC Plan that meets state and federal requirements. 

The Casotte Landing LNG Terminal Project would be constructed on Bayou Casotte, and would 

temporarily impact surface waters of the channel during the dredging to create the proposed marine 

terminal. Water quality in the area being dredged would be temporarily affected by increased turbidity 

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during dredging, but would return to preconstruction conditions following completion of dredging. 

Bayou Casotte Energy has filed SPCC Plans and we have recommended that Bayou Casotte Energy 

develop a plan to include procedures for spills of hazardous materials during offshore activities associated 

with the construction and operation of the marine terminal. 

Because the LNG ships would be fully loaded with LNG when transiting to and arriving at the 

proposed terminal, no ballast water would be discharged into the Mississippi Sound. However, as the 

LNG cargo is unloaded, ballast water would be taken on to maintain trim and stability. LNG ships would 

also use water to cool engines during offloading of LNG at the proposed terminal. 

The LNG terminal was designed to account for an accidental spill of LNG during operation of the 

facility and to prevent any LNG from entering Bayou Casotte Harbor. In the unlikely event that LNG is 

spilled into the water either from the LNG terminal itself or from a ship during transit to the LNG 

terminal, the cryogenic liquid would vaporize rapidly upon contact with the warm air and water. Being 

less dense than water, LNG would float on the surface prior to vaporizing. Because LNG is not soluble in 

water and would completely vaporize shortly after being spilled, the LNG could not mix with or 

contaminate the water. 

The proposed interconnect pipeline would cross two drainage canals. The proposed 

nonjurisdictional NGL pipeline would cross five perennial ditches and one perennial drainage canal. 

Bayou Casotte Energy would cross these waterbodies using the open cut method. To minimize impact on 

surface waters, Bayou Casotte Energy would implement the protective measures outlined in its SWPPP. 

Bayou Casotte Energy would conduct hydrostatic testing activities in accordance with its 

Procedures as well as all applicable permits, including NPDES discharge permits. To minimize effects of 

stormwater runoff during construction of the project, Bayou Casotte Energy would implement measures 

outlined in its Plan and its site-specific SWPPP. 

5.1.4 Vegetation and Wetlands 

Vegetation in the proposed Project area is comprised of upland and wetland communities. 

Construction of the proposed LNG terminal and interconnect pipeline would affect about 117 acres of low 

quality upland vegetation. Much of the vegetation at the proposed terminal site is commercial/industrialassociated vegetation that is fragmented and contains several invasive, exotic species. Most of this 

impact would be permanent because the development of the proposed terminal site would result in a 

permanent conversion of vegetative cover. Following construction, areas not containing new facilities 

would be landscaped with gravel or turf grass at the proposed terminal site. Disturbed upland vegetation 

along the pipeline route would be restored in accordance to Bayou Casotte Energy’s Plan, as modified in 

this EIS. 

Construction of the proposed Casotte Landing LNG Project would directly affect a total of 

146.9 acres of low to medium quality wetlands. Construction at the proposed terminal site would 

permanently affect 119.3 acres of wetlands. The construction of the interconnect pipeline and associated 

meter stations would affect 15.3 acres of wetlands during construction and 7.9 acres during operation. 

The nonjurisdictional NGL pipeline and meter station would affect 12.3 acres of wetlands during 

construction and 0.9 acres during operation. During construction, Bayou Casotte Energy would minimize 

impact on wetlands by implementing measures in its Procedures, as modified in this EIS, and its SWPPP. 

Pursuant to Section 10/404 permit requirements to the COE, Bayou Casotte Energy is proposing 

the purchase of mitigation credits from various mitigation banks and restoration and enhancement of a 

local site to mitigate for the impacts to wetlands. 

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The LNG vessels would transit confined areas between the barrier islands and the mainland, 

where submerged aquatic vegetation and beach dunes are located. The beach dune community on Petit 

Bois Island consists of two distinct plant associations dominated by sea oats on the foredune side and a 

variety of plants such as beach grass, bunch grass, prickly-pear cactus, and golden aster on the protected 

lee side of the dune. 

5.1.5 Wildlife and Aquatic Resources 

The onshore habitats supporting wildlife in the vicinity of the proposed Project have been 

extensively modified by past development and industrial uses. The primary impact on wildlife associated 

with the proposed Project would be clearing of upland and wetland habitat and temporary disturbance 

during construction. Species that may occur at the proposed Project site are typical of disturbed or 

developed areas. While some small, less mobile species could be injured or killed during construction, 

more mobile species would be displaced from the proposed terminal site permanently and temporarily 

from the pipeline right-of-way. Fish and aquatic species that reside in the onshore, low quality 

waterbodies would suffer mortality from the construction activities at the proposed terminal site. All 

construction would be conducted in accordance with the mitigation and restoration requirements 

described in Bayou Casotte Energy’s Plan and Procedures, as modified in this EIS, and impacts to 

onshore wildlife habitat would be minimal. 

The EIS discusses potential impacts on shoreline, estuarine, and marine habitats if LNG were 

released from LNG ship cargo tanks while in transit. Because LNG would vaporize and is a cryogenic 

liquid, we conclude that the greatest threat to aquatic life from an LNG spill would be thermal stress. 

The estuarine benthic habitat in proposed Project area is already frequently disturbed. The fauna 

associated with this benthic habitat is reflective of periodic disturbance and is primarily comprised of 

opportunistic and colonizing invertebrate species. The aquatic habitat occurring in the Bayou Casotte 

water column is also reflective of a developed and previously disturbed setting. Most impacts to marine 

fish would be temporary, as they would be able to avoid the area during construction and operation. 

NOAA Fisheries identified EFH for a variety of managed fish and shellfish species that occur 

within this region, but EFH for 18 individual species and the “billfish and highly migratory species 

group” has the potential to occur within the proposed Project area. The FERC requests that NOAA 

Fisheries consider this EIS as notification of the initiation of EFH consultation. Bayou Casotte Energy 

has been consulting with NOAA Fisheries to develop an acceptable mitigation plan that would 

compensate for adverse impacts on EFH and associated managed species. That EFH Assessment is 

included in this EIS. 

5.1.6 Threatened, Endangered, and Other Special Status Species 

The FWS and NOAA Fisheries have identified a total of 26 federally listed endangered or 

threatened species that could potentially occur in the vicinity of the proposed Project. We conclude that 

11 of these species do not occur in the proposed Project area or would not be affected by the construction 

and operation of the proposed LNG facilities based on field surveys, initial agency consultations, and 

review of existing information. The remaining 15 species that the proposed Project could encompass 

habitat for include six whales (sperm whale, blue whale, sei whale, fin whale, humpback whale, North 

Atlantic right whale), the Florida manatee, the Gulf sturgeon, five turtles (hawksbill sea turtle, green sea 

turtle, Kemp’s ridley sea turtle, leatherback sea turtle, and loggerhead sea turtle), and two birds (bald 

eagle and brown pelican). 

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Based on our analysis of habitat that would be affected by the Project, Bayou Casotte Energy’s 

proposed mitigation, and our recommended mitigation measures such as the implementation of the Strike 

Avoidance Procedures and special pile driving procedures, we have determined that the proposed Project 

would either have no effect or would not likely adversely affect these species. Consultations with the 

FWS and NOAA Fisheries are ongoing. 

5.1.7 Land Use, Recreation, and Visual Resources 

The nearest residences to the property boundary of the proposed LNG terminal are about 1.0 mile 

northwest of the terminal. The residences in this area were severely damaged or destroyed by Hurricane 

Katrina. We assumed that these residences would be rebuilt and, therefore, continued to use them as the 

closest residences for the purposes of evaluating impacts associated with construction and operation of the 

LNG terminal. Temporary construction impacts on these residences could include inconvenience caused 

by noise generated during pile driving activities associated with the installation of the proposed facilities. 

Permanent impacts on residences associated with operation of the proposed LNG terminal include those 

on visual resources. 

Two planned industrial developments have been identified in the immediate vicinity of the 

proposed LNG terminal site. One, the expansion at the Chevron Pascagoula Refinery, is proposed within 

the existing boundary of the refinery and so adverse impacts are not expected. The other is an LNG 

terminal whose application is currently being reviewed by the FERC. The land adjacent to the proposed 

pipeline route is largely industrial with no private residences located within 50 feet of any proposed 

workspace. The land required for the proposed Project is all privately owned with the nearest special use 

area being Grand Bay National Estuary Research Reserve about one mile from the proposed Project site. 

While LNG carriers are on their inbound and outbound routes or docked, other vessels, including 

recreational boats, would be prohibited within any safety/security zones that may be established by the 

Coast Guard. These effects would be temporary while the boat is in transit or moored at the ship 

unloading facility. The maximum delay expected due to the transit of a LNG carrier would be 1.5 hours. 

The extent of the security zone around the LNG ship while it is unloading would be established by the 

Coast Guard but is not expected to interfere with traffic along the adjacent Bayou Casotte Channel. 

The most prominent visual features of the proposed LNG terminal would be three LNG storage 

tanks, each about 168 feet in height. The height of the LNG storage tanks would be about 68 feet taller 

than the tallest structure on the adjacent Pascagoula Refinery. While the LNG storage tanks would be 

visible from surrounding locations, they would be consistent with existing views of adjacent industrial 

facilities, and would not represent a significant visual impact. Ship traffic is common in Bayou Casotte, 

and would be similar to existing practices and not substantially change the visual character of the area. 

The visual impact of the proposed pipeline and associated aboveground facilities, all of which are in 

direct proximity to existing industrial facilities, would not represent a significant change to the aesthetics 

of the landscape. 

In Mississippi the MDMR and the Pascagoula Special Management Area are responsible for 

reviewing federal agency actions and activities to ensure that they are consistent with Mississippi’s CMP. 

We have recommended that Bayou Casotte Energy not be allowed to begin construction until it has 

received documentation confirming that the Project, including LNG vessel transit in Mississippi’s 

waterway, is consistent with the Mississippi’s CMP. 

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5.1.8 Socioeconomics 

During the two years of peak construction activity, Bayou Casotte Energy would employ 400 to 

600 workers. About 50 full-time employees would be needed for operation of the proposed Project 

facilities. Annual permanent wages for these employees would be about $3million. The addition of nonlocal workers would not represent a significant increase to the Jackson County Mississippi population 

though, depending on reconstruction following Hurricane Katrina, construction related demand for 

housing could result in a minor to moderate tightening of the housing market. Local infrastructure and 

public services were sufficient to handle project needs prior to the hurricane and it is likely that they will 

be prepared to absorb project related workers by 2007. Any additional strain on public service provision 

would likely be offset by an increase in the local tax base. The proposed Project should not have an 

adverse effect on local property values, and would not disproportionately impact any minority or lowincome neighborhoods. The proposed Project would benefit the local economy through expenditures for 

wages, purchase of materials, and taxes. 

We have not identified any high and adverse human health or environmental effects that would be 

borne disproportionately by any minority or low-income group. 

5.1.9 Transportation and Traffic 

Traffic generated during peak construction of the LNG terminal would increase by an estimated 

5 percent over existing daily traffic volume on Highway 611, the only access route to the proposed 

terminal. While this would not be a significant impact on traffic flow on Highway 611, there could be 

significant impacts on interchanges and intersections leading to the proposed LNG terminal site. Bayou 

Casotte Energy would try to alleviate these impacts by having workers arrive before peak commuting 

times and delivering most materials to the proposed site via marine transport or limiting deliveries to offpeak transportation times. We have recommended that Bayou Casotte Energy file the outcome of 

consultations with the MDOT and Jackson County regarding the need for traffic mitigation measures. 

The proposed project would not have a significant impact on traffic during operation. 

During operation, the LNG terminal would receive up to 170 LNG carriers per year, resulting in 

an average of one vessel every two days through the Pascagoula and Bayou Casotte Channels, if 

determined to be suitable waterways by the Coast Guard. Along with the anticipated addition of 

150 carriers from the Gulf Energy LNG Project, both projects have the potential to increase the number of 

LNG carriers by up to 320 LNG carriers per year, however, neither of these projects is located in an area 

of high recreation value or usage. Therefore, the proposed LNG terminal projects could only have 

minimal affects on recreational activities in the area. Other shipping activities would be moderately 

affected by the increase in traffic; however, based on the relatively low volume of existing shipping 

activity in the berthing area to the territorial sea, the impact is not expected to be substantial. 

Safety measures and the size of the LNG carriers may require specific transit procedures within 

the Bayou Casotte Channel (e.g., daylight movements, one-way traffic, convoys). However, the Pilots 

(which are responsible for scheduling ship movements and establishing working conditions) indicated 

that they could continue to escort ships into and out of the channels in a safe and expeditious manner and 

that the Project would have minimal impacts on ship traffic. In a letter dated April 1, 2006, and modified 

in a letter dated September 5, 2006, the Coast Guard made a preliminary determination that the 

Pascagoula Bar, Horn Island Pass, Lower Pascagoula, and Bayou Casotte Channels may be suitable for 

the marine traffic associated with the Casotte Landing LNG Terminal Project. 

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5.1.10 Cultural Resources 

Bayou Casotte Energy has conducted cultural resource surveys and filed with the FERC and the 

Mississippi SHPO survey reports for the proposed LNG terminal, pipelines, and interconnects. The 

Mississippi SHPO has issued its concurrence that the LNG terminal, pipeline, and interconnect facilities 

would not affect cultural or historic resources; therefore, no mitigation would be required. 

The LNG marine traffic would transit along the waterway from the territorial seas to the berthing 

facility, passing through the Horn Island Pass. In the unlikely event of an LNG spill along the waterway, 

the physical properties of LNG would limit any potential impacts to cultural resources on either Horn or 

Petit Bois Island. 

Bayou Casotte Energy filed with its application an accepted Unanticipated Discoveries Plan to be 

used in the event that cultural resources or human remains are discovered during construction. The plan 

describes the procedures that would be undertaken in the event previously unidentified cultural resources 

or human remains are encountered during construction. 

Bayou Casotte Energy contacted the Mississippi Band of Choctaw Indians whose traditional 

territory would be directly affected by the proposed project. To date, the tribe has not requested any 

information regarding the proposed project. 

5.1.11 Air Quality and Noise 

Air emissions resulting from construction of the proposed Casotte Landing LNG Terminal would 

be temporary and intermittent. Bayou Casotte Energy would minimize dust emissions through 

application of water. Based on the nature of these emissions and level of mitigation that will be used the 

construction emissions would not significantly affect air quality in the region. Air emissions from 

operation of the LNG terminal would be low because the equipment would burn natural gas. The 

proposed LNG terminal would be a minor source of air emissions under the PSD regulations. The marine 

vessels associated with the proposed LNG terminal operation would generate the vast majority of the air 

emissions during transportation to the terminal and berthing at the terminal. Dispersion modeling 

indicates that these vessel emissions would not exceed a NAAQS. 

Bayou Casotte Energy also conducted a quantitative assessment of project air emissions. The 

assessment included air dispersion modeling analyses to predict off-site (i.e., ambient) concentrations in 

the vicinity of the project resulting from the proposed emissions associated with operation of the project 

for comparison to appropriate federal air quality standards. The modeled project emissions plus 

background concentration was less than the NAAQS which demonstrated that the project primary sources 

would not have a significant impact on NAAQS compliance. Bayou Casotte Energy also modeled 

emissions from primary and secondary sources and their impacts on the Class I area at Breton National 

Wildlife Refuge (BNWR). Results for each pollutant demonstrated that the Proposed Project would have 

no significant impacts on the NAAQS at BNWR. 

During operation of the Casotte Landing Project, air emissions from LNG marine traffic and 

other project-related vessels would occur along the entire waterway from the territorial seas to the ship 

berth. The emissions to any one localized area during ship transit would be temporary and transient and 

would be occurring at distances allowing for considerable dispersion before reaching any sensitive 

receptors; therefore, air emissions from ship transit are not expected to result in a significant impact on air 

quality. 

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No operational emissions from the sendout pipeline would be regulated by the MDEQ or EPA air 

quality regulations. Operational emissions would be limited to blowdown emissions that would occur 

during emergency situations and fugitive emissions during operation. Blowdowns would rarely occur and 

fugitive emissions would be negligible due to the small amount of natural gas emitted and the small 

fraction of VOCs contained in the natural gas. Therefore, these emissions would not have a significant 

effect on air quality. 

Noise would be generated during construction of the pipeline and during construction and 

operation of the proposed LNG terminal. In most areas, the increase in noise during construction would 

be localized, temporary, and limited primarily to daylight hours. Noise associated with dredging 

operations, however, could occur up to 24 hours a day for a period of at least 6 months. The predicted 

noise levels at the nearest NSA during excavation, dredging, and pile driving at the proposed LNG 

terminal, would be below the FERC’s threshold of an Ldn of 55 dBA and below existing ambient noise 

levels. Although construction activities at the proposed LNG terminal may be audible during relatively 

quiet periods, noise-related impacts are expected to be minimal and no mitigation would be required. 

Noise impacts during construction of the pipeline would be short term and temporary at any one place 

because of the assembly line method of pipeline construction. Based on noise attenuation computer 

modeling, noise from the proposed LNG terminal may be perceptible during relatively quiet periods, but 

the facility would not contribute substantially to typical existing background noise conditions. The actual 

noise generated during operation of the LNG terminal may be different from those obtained from 

modeling; therefore we have recommended that Bayou Casotte Energy make all reasonable efforts to 

assure its predicted noise levels from the LNG terminal are not exceeded at the NSAs; conduct noise 

surveys to confirm that compliance with our standard has been achieved; and file the results of the survey 

with the Secretary no later than 60 days after placing the LNG terminal in service. 

Noise generated by LNG ships along the waterway from the territorial seas to the LNG terminal 

would be similar to noise from other large ships using the waterway. Underwater noise would cause a 

local and temporary avoidance behavior in fish but would not result in significant adverse impacts. 

Above-water noise associated with the LNG vessels would not result in significant impacts on 

environmental resources. 

5.1.12 Reliability and Safety 

We evaluated the safety of both the proposed facilities and the related LNG vessel transit through 

the Pascagoula Bar, Horn Island Pass, Lower Pascagoula, and Bayou Casotte Channels. As part of our 

evaluation, we performed a cryogenic design and technical review of the proposed terminal design and 

safety systems. Several areas of concern were noted with respect to the proposed facility, and specific 

recommendations have been identified to be addressed: prior to initial site construction; prior to 

construction after final design; prior to commissioning; or prior to commencement of service. 

Thermal radiation and flammable vapor hazard distances were calculated for an accident or an 

attack on an LNG vessel. For 1-, 1.5-, 2.5-, 3.0-, and 3.9-meter-diameter holes in an LNG cargo tank, we 

estimated distances to range from 2,164 to 5,250 feet for a thermal radiation level of 1,600 Btu/hr/ft2

, the 

level which is hazardous to unprotected persons located outdoors. Based on a 1-meter-diameter hole, an 

unignited release would result in an estimated pool radius of 421 feet. The unignited vapor cloud would 

extend to 9,776 feet to the lower flammability limit and 14,377 feet to one-half the lower flammability 

limit. Flammable vapor dispersion for larger holes was not performed since, realistically, the cloud would 

not even extend to the maximum distance for a 1-meter-diameter hole before encountering an ignition 

source. However, the evaluation of safety is more than an exercise in calculating the consequences of 

worst case scenarios. Rather, it is a determination of the acceptability of risk which considers: the 

probability of events, the effect of mitigation, and the consequences of events. Based on the extensive 

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

controls that may be imposed by the Coast Guard and the local pilots, the likelihood of a cargo 

containment failure and subsequent LNG spill from a vessel casualty – collision, grounding, or allision – 

is highly unlikely. For similar reasons, an accident involving the onshore LNG import terminal is 

unlikely to affect the public. As a result, the risk to the public from accidental causes should not be 

considered significant. 

As part of our marine safety analysis, we considered how vessel security requirements for LNG 

carriers calling on the proposed LNG terminal might affect other ship and boat traffic in the Pascagoula 

Bar, Horn Island Pass, Lower Pascagoula, and Bayou Casotte Channels. Based on the Coast Guard’s 

longstanding experience in controlling the movements of dangerous cargo vessels and LNG vessels in 

other ports, potential impacts can be evaluated for several general security requirements: 1) moving safety 

zone for inbound and outbound LNG vessels; 2) security zone around a moored LNG vessel; and 3) other 

measures as deemed appropriate. If the Coast Guard issues a LOR finding the waterway suitable for LNG 

marine traffic, the moving safety zone, and the security zone at the terminal, may affect other commercial 

and recreational traffic using the waterway. 

The extent of the impact on recreational boaters would depend on the number of boats in the 

project area during the two to three LNG vessel transits per week when LNG ships would call on the 

LNG terminal, and on several other variables such as the size of the possible Coast Guard-imposed 

moving safety and moored security zone and the width of the channel at the point where a boat encounters 

the LNG ship. To minimize potential impacts on other marine traffic, the Coast Guard is expected to use 

a program of announcements to give advance notice of each moving safety and moored security zone 

schedule and could schedule the transit of LNG marine traffic for times of day less likely to affect 

recreational boaters. 

Unlike accidental causes, historical experience provides little guidance in estimating the 

probability of a terrorist attack on an LNG vessel or onshore storage facility. For an LNG import terminal 

proposal that would involve having a large volume of energy transported and stored, the perceived threat 

of a terrorist attack is a primary concern of the local population and requires that resources be directed to 

mitigate possible attack paths. While the risks associated with the transportation of any hazardous cargo 

can never be entirely eliminated, they can be managed. 

An issue that has developed for several LNG terminal projects is a concern that local 

communities would have to bear some of the costs of ensuring the security/emergency management of the 

LNG facility and the LNG vessel while in transit and unloading at the dock. The specific 

security/emergency management costs for the proposed project are not yet available. The final costs 

associated with security would be determined after the specific security needs and responsibilities have 

been established by the Coast Guard through consultations with other federal, state, and local agencies. 

In accordance with 33 CFR 127.007, Bayou Casotte Energy submitted a LOI to the Coast Guard 

on February 10, 2005 conveying its intention to construct and operate an LNG import terminal at the 

proposed site. On February 13, 2006, Bayou Casotte Energy submitted its WSA to the Coast Guard in 

accordance with the guidance in NVIC 05-05. The Coast Guard, with input from Pascagoula AMSC, has 

completed an initial review of Bayou Casotte Energy’s WSA in accordance with the guidance in NVIC 

05-05. 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. 

On September 5, 2006, the Coast Guard sent a letter to FERC, based on the above WSA and 

AMSC review, providing preliminary 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. As 

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described in this document, the Coast Guard has preliminarily determined that the Pascagoula Bar, Horn 

Island Pass, Lower Pascagoula and Bayou Casotte Channels are suitable for the LNG marine traffic 

associated with this project contingent on the evaluation of certain conditions before a final determination 

of suitability can be made. With the completion of this final EIS, the Coast Guard will complete its 

review and issue an LOR with conditions to address the suitability of the waterways for LNG transport. 

While a typical LOR would address the suitability of the waterway from the berthing area to the 

territorial sea for LNG marine transit, it would not constitute a final authority to commence LNG 

operations. The Coast Guard’s LNG Vessel Transit Management Plan would be developed in conjunction 

with state and local law enforcement and emergency response communities. As a condition of the LOR, 

the Coast Guard may establish a moving safety zone and moored vessel security zone under 33 CFR 165 

for LNG vessels in transit and while docked. Only personnel or vessels authorized by the COTP are 

permitted within these zones. 

Once the plan is finalized and the resources required to implement it have been identified, Bayou 

Casotte Energy will be able to more specifically discuss the funding of such resources. In order to better 

define how the potential burden on local communities would be addressed, we have recommended that 

Bayou Casotte Energy provide a Cost-Sharing Plan that identifies the mechanisms for funding projectspecific security/emergency management costs that would be imposed on state agencies and local 

communities. 

5.1.13 Alternatives 

As an alternative to the proposed action, we evaluated the no action or postponed action 

alternatives, system alternatives, LNG terminal site alternatives, LNG terminal design alternatives, 

pipeline interconnect alternatives, and dredge material placement alternatives. While the no action or 

postponed action alternative would eliminate the short- and long-term environmental impacts identified in 

this EIS, the objectives of the proposed Project would not be met, and Bayou Casotte Energy would not 

be able to provide a new source of natural gas to markets that can be accessed through the proposed 

pipeline interconnects. 

Our analysis of system alternatives included an evaluation of whether existing and proposed LNG 

and other natural gas systems could meet the proposed Project objectives while offering an environmental 

advantage over the proposed Project. We considered both existing onshore and offshore LNG terminals, 

as well as existing natural gas pipeline systems. In addition, we also analyzed various recently approved 

and proposed projects, including the construction of an offshore terminal, to meet the objectives of the 

proposed Casotte Landing Project. Pipeline system alternatives would not provide new, non-domestic 

sources of natural gas, and therefore be unable to meet the objectives of the proposed Project. Relative to 

the proposed Project, it is unclear how efficiently or effectively, the other existing, approved, and 

proposed onshore LNG terminal projects could satisfy the objectives of the proposed Casotte Landing 

Project. However, the FERC does not ultimately view any of the existing, approved, or proposed onshore 

LNG terminal projects as true alternatives to the proposed Project. Rather we view each as potentially 

complementary for the purpose of meeting the United States’ projected energy demands. We 

acknowledge that some of the existing, approved, and proposed offshore LNG terminal projects could 

provide an alternative means for the import of LNG, but we do not consider that any of them would 

provide the capabilities of the proposed Project. Further, we do not consider that any of the offshore LNG 

terminal technologies represent an environmentally preferable or technically and economically feasible 

and practical alternative to the proposed Project. 

The proximity of the proposed terminal site to the Chevron Pascagoula Refinery would provide 

numerous synergies and environmental benefits, including use of existing services for security and safety, 

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minimization of landowner impacts, and use of waste heat from the Refinery to accomplish LNG 

vaporization. We also considered that other potential locations would be unlikely to satisfy the proposed 

Project objectives. Therefore, we did not conduct a detailed regional screening analysis to identify 

alternative terminal locations. However, we did consider local siting alternatives for the proposed LNG 

terminal. We also considered LNG terminal design alternatives, including four terminal slip 

configuration alternatives, five vaporization technology alternatives, and electrical power system 

alternatives, as well as route alternatives for the proposed pipeline interconnect spur. However, relative to 

the proposed Project none of the alternatives evaluated were considered environmentally preferable 

and/or technically and economically feasible. In summary, we have determined that the proposed Project, 

as modified by our recommended mitigation measures, is the preferred alternative that can meet the 

Project objectives. 

Lastly, we evaluated four general alternatives for placement of the 3.5 mcy of initial and 

250,000 yd3

 of annual maintenance dredge material that would result from construction and operation of 

the proposed Project. Bayou Casotte Energy indicates that its preferred alternative for placement of both 

construction and maintenance dredge materials is placement at the ODMDS, with contribution to 

beneficial use sites as available. Pending receipt of the required approvals under Section 103 of the 

MPRSA, we do not consider any of the dredge material placement alternatives evaluated to represent a 

technically or environmentally preferable alternative to Bayou Casotte Energy’s preferred dredged 

material placement plan. 

The preferred alternative for the Coast Guard is to issue an LOR finding the waterway suitable for 

LNG vessel traffic with conditions. These conditions include: 1) establishment of a moving safety zone 

during LNG vessels’ transit of the waterway, including requirements for daylight transit and one way 

LNG vessel traffic on the waterway, as well as another safety zone around the LNG facility while the 

LNG vessels are moored; 2)an annual review of the facility’s Waterway Suitability Assessment by the 

applicant to evaluate if any conditions in the waterway have changed that would require issuance of a new 

LOR, with submittal of such annual reviews to the COTP for consideration and issuance of a new LOR, if 

required; 3) LNG vessels must navigate the waterway from the outer sea buoy to the berthing with harbor 

pilots onboard; 4) that tug assistance be provided as deemed necessary by the Pascagoula pilots; 5) that all 

LNG traffic make a SECURITE broadcast prior to crossing the Gulf Intracoastal Waterway; 6) 

implementation of a Coast Guard approved LNG Vessel Transit Management Plan; and 7) that adequate 

Coast Guard resources be available to implement the security measures described above. If these 

conditions to the LOR are imposed, the potential for accidental releases or releases resulting from terrorist 

attacks would be minimized. Considering this and the other potential environmental impacts discussed in 

this EIS, the total potential for adverse environmental impacts resulting from the Coast Guard’s proposed 

action is not considered significant. 

If a LOR is issued without conditions, the potential for accidental releases or releases from 

terrorist attacks would increase, increasing the potential adverse environmental impacts that are discussed 

in this EIS. If a LOR is issued determining that the waterway is unsuitable for LNG traffic, then the 

potential for additional adverse environmental impacts would be avoided, but this would not provide the 

United States with LNG as an alternative energy source. If issuing the LOR is delayed, any potential 

environmental impacts would only be delayed. However, this alternative would delay providing the 

United States with a sufficient alternate source of energy. 

The preferred alternative of issuing a LOR with the referenced conditions will allow the LNG 

vessels to reach the facility with potentially less adverse environmental impacts than issuing a LOR 

finding the waterway to be suitable for LNG vessel traffic without conditions, and provide an alternate 

source of energy which will supplement/replace the use of non-renewable sources such as coal and 

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petroleum products and renewable nuclear fuels, and reducing our dependency on petroleum and nuclear 

fuels. 

In conclusion, we have determined that Bayou Casotte Energy’s proposed project, as modified by 

our recommended mitigation measures, is the preferred alternative that can meet the project objectives. 

5.2 FERC STAFF’S RECOMMENDED MITIGATION 

If the Commission approves the proposed Casotte Landing LNG Terminal Project, we 

recommend that the Commission’s authorizations include the measures recommended below. We believe 

these measures would further mitigate the environmental impacts associated with the construction and 

operation of the proposed Project. 

1. Bayou Casotte Energy shall follow the construction procedures and mitigation measures described in 

its application, supplemental filings (including responses to staff data requests) and as identified in 

the environmental impact statement (EIS), unless modified by the Order. Bayou Casotte Energy 

must: 

a. request any modification to these procedures, measures, or conditions in a filing with the 

Secretary of the Commission (Secretary); 

b. justify each modification relative to site-specific conditions; 

c. explain how that modification provides an equal or greater level of environmental protection than 

the original measure; and 

d. receive approval in writing from the Director of the Office of Energy Projects (OEP) before 

using that modification. 

2. For pipeline facilities, the Director of OEP has delegated authority to take whatever steps are 

necessary to ensure the protection of all environmental resources during construction and operation of 

the Casotte Landing LNG Terminal (Project). This authority shall allow: 

a. the modification of conditions of the Commission’s Order; and 

b. the design and implementation of any additional measures deemed necessary (including stop 

work authority) to assure continued compliance with the intent of the environmental conditions as 

well as the avoidance or mitigation of adverse environmental impact resulting from project 

construction and operation. 

3. For liquefied natural gas facilities, the Director of OEP has delegated authority to take all steps 

necessary to ensure the protection of life, health, property, and the environment during construction 

and operation of the Project. This authority shall include: 

a. stop-work authority and authority to cease operation; and 

b. the design and implementation of any additional measures deemed necessary to assure continued 

compliance with the intent of the conditions of the Order. 

4. Prior to any construction, Bayou Casotte Energy shall file an affirmative statement with the Secretary, 

certified by a senior company official, that all company personnel, environmental inspectors, and 

contractor personnel will be informed of the environmental inspector’s authority and have been or 

will be trained on the implementation of the environmental mitigation measures appropriate to their 

jobs before becoming involved with construction and restoration activities. 

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5. The authorized facility locations shall be as shown in the EIS, as supplemented by filed alignment 

sheets, and shall include all of the staff's recommended facility locations. As soon as they are 

available, and before the start of construction, Bayou Casotte Energy shall file with the Secretary 

any revised detailed survey alignment maps/sheets at a scale not smaller than 1:6,000 with station 

positions for all facilities approved by the Order. All requests for modifications of environmental 

conditions of the Order or site-specific clearances must be written and must reference locations 

designated on these alignment maps/sheets. 

6. Bayou Casotte Energy shall file with the Secretary detailed alignment maps/sheets and aerial 

photographs at a scale not smaller than 1:6,000 identifying all route realignments or facility 

relocations, and staging areas, pipe storage yards, new access roads, and other areas that would be 

used or disturbed and have not been previously identified in filings with the Secretary. Approval for 

each of these areas must be explicitly requested in writing. For each area, the request must include a 

description of the existing land use/cover type, and documentation of landowner approval, whether 

any cultural resources or federally listed threatened or endangered species would be affected, and 

whether any other environmentally sensitive areas are within or abutting the area. All areas shall be 

clearly identified on the maps/sheets/aerial photographs. Each area must be approved in writing by 

the Director of OEP before construction in or near that area. 

This requirement does not apply to extra workspace allowed by the Upland Erosion Control, 

Revegetation, and Maintenance Plan (Plan), minor field realignments per landowner needs, and 

requirements which do not affect other landowners or sensitive environmental areas such as wetlands. 

Examples of alterations requiring approval include all route realignments and facility location 

changes resulting from: 

a. implementation of cultural resources mitigation measures; 

b. implementation of endangered, threatened, or special concern species mitigation measures; 

c. recommendations by state regulatory authorities; and 

d. agreements with individual landowners that affect other landowners or could affect sensitive 

environmental areas. 

7. At least 60 days before that start of construction, Bayou Casotte Energy shall file an initial 

Implementation Plan with the Secretary for review and written approval by the Director of OEP 

describing how Bayou Casotte Energy will implement the mitigation measures required by the Order. 

Bayou Casotte Energy must file revisions to the plan as schedules change. The plan shall identify: 

a. how Bayou Casotte Energy will incorporate these requirements into the contract bid documents, 

construction contracts (especially penalty clauses and specifications), and construction drawings 

so that the mitigation required at each site is clear to onsite construction and inspection personnel; 

b. the number of environmental inspectors assigned per spread, and how the company will ensure 

that sufficient personnel are available to implement the environmental mitigation; 

c. company personnel, including environmental inspectors and contractors, who will receive copies 

of the appropriate material; 

d. the training and instructions Bayou Casotte Energy will give to all personnel involved with 

construction and restoration (initial and refresher training as the Project progresses and personnel 

change), with the opportunity for OEP staff to participate in the training session(s); 

e. the company personnel (if known) and specific portion of Bayou Casotte Energy’s organization 

having responsibility for compliance; 

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f. the procedures (including use of contract penalties) Bayou Casotte Energy will follow if 

noncompliance occurs; and 

g. for each discrete facility, a Gantt or PERT chart (or similar project scheduling diagram), and 

dates for: 

(1) the completion of all required surveys and reports; 

(2) the mitigation training of onsite personnel; 

(3) the start of construction; and 

(4) the start and completion of restoration. 

8. Bayou Casotte Energy shall develop and implement an environmental complaint resolution 

procedure. The procedure shall provide landowners with clear and simple directions for identifying 

and resolving their environmental mitigation problems/concerns during construction of the Project 

and restoration of the right-of-way. Prior to construction of the pipeline, Bayou Casotte Energy 

shall mail the complaint procedures to each landowner whose property would be crossed by the 

Project. 

a. In its letter to affected landowners, Bayou Casotte Energy shall: 

(1) provide a local contact that the landowners should call first with their concerns; the letter 

should indicate how soon a landowner should expect a response; 

(2) instruct the landowners that, if they are not satisfied with the response, they should call 

Bayou Casotte Energy’s Hotline; the letter should indicate how soon to expect a response; 

and 

(3) instruct the landowners that, if they are still not satisfied with the response from Bayou 

Casotte Energy’s Hotline, they should contact the Commission's Enforcement Hotline at 

(888) 889-8030. 

b. In addition, Bayou Casotte Energy shall include in its weekly status report a copy of a table that 

contains the following information for each problem/concern: 

(1) the date of the call; 

(2) the identification number from the certificated alignment sheets of the affected property; 

(3) the description of the problem/concern; and 

(4) an explanation of how and when the problem was resolved, will be resolved, or why it has not 

been resolved. 

9. Bayou Casotte Energy shall employ an environmental inspector (EI). The environmental inspector 

shall be: 

a. responsible for monitoring and ensuring compliance with all mitigation measures required by the 

Order and other grants, permits, certificates, or other authorizing documents; 

b. responsible for evaluating the construction contractor's implementation of the environmental 

mitigation measures required in the contract (see condition 6 above) and any other authorizing 

document; 

c. empowered to order correction of acts that violate the environmental conditions of the Order, and 

any other authorizing document; 

d. a full-time position, separate from all other activity inspectors; 

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e. responsible for documenting compliance with the environmental conditions of the Order, as well 

as any environmental conditions/permit requirements imposed by other federal, state, or local 

agencies; and 

f. responsible for maintaining status reports. 

10. Bayou Casotte Energy shall file updated status reports prepared by the EI with the Secretary on a 

weekly basis until all construction and restoration activities are complete. On request, these 

status reports will also be provided to other federal and state agencies with permitting responsibilities. 

Status reports shall include: 

a. the current construction status of the Project, work planned for the following reporting period, 

and any schedule changes for stream crossings or work in other environmentally sensitive areas; 

b. a listing of all problems encountered and each instance of noncompliance observed by the EI(s) 

during the reporting period (both for the conditions imposed by the Commission and any 

environmental conditions/permit requirements imposed by other federal, state, or local agencies); 

c. corrective actions implemented in response to all instances of noncompliance, and their cost; 

d. the effectiveness of all corrective actions implemented; 

e. a description of any landowner/resident complaints which may relate to compliance with the 

requirements of the Order, and the measures taken to satisfy their concerns; and 

f. copies of any correspondence received by Bayou Casotte Energy from other federal, state or local 

permitting agencies concerning instances of noncompliance, and Bayou Casotte Energy’s 

response. 

11. Bayou Casotte Energy must receive written authorization from the Director of OEP before

commencing service of the LNG terminal and the other components of the project. Such 

authorization will only be granted following a determination that the facilities have been constructed 

in accordance with FERC approval and applicable standards, can be expected to operate safely as 

designed, and the rehabilitation and restoration of the right-of-way is proceeding satisfactorily. 

12. Within 30 days of placing the certificated facilities in service, Bayou Casotte Energy shall file an 

affirmative statement with the Secretary, certified by a senior company official: 

a. that the facilities have been constructed in compliance with all applicable conditions, and that 

continuing activities will be consistent with all applicable conditions; or 

b. identifying which of the certificate conditions Bayou Casotte Energy has complied with or will 

comply with. This statement shall also identify any areas affected by the Project where 

compliance measures were not properly implemented, if not previously identified in filed status 

reports, and the reason for noncompliance. 

13. Bayou Casotte Energy shall file with the Commission before construction the following information 

on nonjurisdictional facilities, including the Mississippi Power Company transmission lines and 

substations, the Refinery berth relocations, and the NGL extraction and pipeline system: 

a. final routing and design information, including a map depicting the location of the facilities; 

b. documentation of consultations with the appropriate agencies and the status of federal, state, or 

local permits or approvals required for construction; and 

c. status and copies of agency clearances (or copies of any surveys and reports prepared) for 

wetlands, threatened and endangered species, and cultural resources. 

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14. Bayou Casotte Energy shall revise its proposed Plan, except for the proposed variances specifically 

approved in this EIS, to be consistent with the FERC’s standard Plan. The revised Plan shall be filed 

with the Secretary for review and written approval by the Director of OEP prior to the start of 

construction. EIS Section 4.2.1

15. Bayou Casotte Energy shall develop a plan in consultation with the MDEQ and EPA regarding 

assessment, containment, and disposal of contaminated groundwater that might be encountered during 

any construction activities and file a copy with the Secretary prior to the start of construction. EIS 

Section 4.3.1

16. Except for the proposed variances specifically approved within this EIS, Bayou Casotte Energy shall 

revise its proposed Procedures to be consistent with the FERC's standard Procedures, as modified in 

this EIS. The revised Procedures should be filed with the Secretary for review and written approval 

by the Director of OEP prior to construction. EIS Section 4.3.2

17. Bayou Casotte Energy shall file the results of consultations with MDEQ regarding the use of 

hydrostatic test water additives to the Commission prior to the start of construction, and not use 

corrosion inhibitors, biocides, oxygen scavengers, or other hydrostatic test water additives that exhibit 

toxicity to aquatic organisms without prior written approval by the Director of OEP. EIS Section 

4.3.2

18. Bayou Casotte Energy shall complete consultations with MDMR and MDEQ regarding potential 

impacts to water quality within or adjacent to the proposed terminal slip and file documentation of the 

consultation findings and any required mitigation or monitoring measures to the Secretary prior to 

the date of construction. EIS Section 4.3.2

19. Bayou Casotte Energy shall implement the lighting guidelines developed by the FWS for siting, 

construction, operation, and decommissioning of communication towers. These guidelines 

specifically recommend that the number and intensity of facility lighting be minimized and that 

security lighting be down-shielded to keep light within the boundaries of the site. Bayou Casotte 

Energy shall file that plan with the Secretary for review and written approval by the Director or OEP 

prior to construction. EIS Section 4.5.1

20. Bayou Casotte Energy shall complete consultations with the MDMR regarding the need for a preconstruction and post-construction project trawl and benthic sampling plan and if required, file the 

agency approved plan with the Secretary prior to the start of construction. EIS Section 4.5.2

21. Bayou Casotte Energy shall complete consultations with NOAA Fisheries and MDMR regarding 

potential impacts to ichthyoplankton and aquatic resources resulting from the intake of ballast and 

engine cooling water, the discharge of cooling water, (and all other activities that result in withdrawal 

of marine surface water, such as hydrostatic testing and maintenance dredging), and file the findings 

of these consultations with the Commission, including any required or recommended measures to 

prevent or reduce impacts, prior to the start of construction. EIS Section 4.5.2

22. Bayou Casotte Energy shall finalize consultations with NOAA Fisheries, MDMR, and the COE to 

develop a plan for quantifying, if appropriate, and mitigating impacts to EFH and file that plan with 

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

Section 4.5.4

23. Bayou Casotte Energy shall consult with the FWS regarding appropriate measures that should be 

implemented to avoid or minimize impacts to migratory bird species if construction activities were to 

occur during peak nesting season (April 1 through June 30). In addition, Bayou Casotte Energy shall 

file the results of that consultation with the Secretary and receive written approval from the Director 

of OEP prior to implementing any associated mitigation measures. EIS Section 4.6.2

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24. Bayou Casotte Energy shall not begin construction activities at the LNG terminal and along the 

pipeline route until: 

a. the FERC completes any necessary consultations with the FWS and NOAA Fisheries; and 

b. Bayou Casotte Energy receives written notification from the Director of OEP that construction 

and/or implementation of conservation measures may begin. 

If construction has not begun within 1 year from the date of issuance of the FERC approval of the 

project, Bayou Casotte Energy shall consult with the appropriate offices of the FWS and NOAA 

Fisheries to update the species list and to verify that previous consultations and determinations of 

effect are still current. Documentation of these consultations, and the need for additional surveys and 

survey reports (if required), and FWS or NOAA Fisheries comments on the surveys and survey 

reports and their conclusions, shall be filed with the Secretary and the COTP prior to construction. 

EIS Section 4.6.3

25. Bayou Casotte Energy shall file documentation of concurrence from the Mississippi Department of 

Marine Resources that the Project is consistent with Mississippi’s CMP with the Secretary prior to 

construction. EIS Section 4.7.5

26. Bayou Casotte Energy shall file with the Secretary the outcome of consultations with state and local 

transportation authorities to determine the need for Maintenance of Traffic Study prior to the 

initiation of construction. EIS Section 4.9.2

27. Bayou Casotte Energy prepare a Fugitive Dust Control Plan that specifies the following: 

a. The precautions that would be taken to minimize fugitive dust emissions from construction 

activities and when/how the measures would be applied; 

b. the individuals with the authority to determine if/when water needs to be reapplied for dust 

control; and 

c. the individuals with the authority to stop work if the contractor does not comply with dust control 

measures. 

This plan should be filed with the Secretary for review and written approval of the Director of OEP 

prior to the start of construction activities. EIS Section 4.11.1 

28. Bayou Casotte Energy shall make all reasonable efforts to ensure its predicted noise levels from the 

LNG terminal are not exceeded at the noise-sensitive area (NSA) and file noise surveys with the 

Secretary no later than 60 days after placing the LNG terminal in service. However, if the noise 

attributable to the operation of the LNG terminal exceeds 55 decibels on the A-weighted scale daynight sound level at a NSA, Bayou Casotte Energy shall file a report on what changes are needed and 

shall install additional noise controls to the level within 1 year of the in-service date. Bayou Casotte 

Energy shall confirm compliance with these requirements by filing a second noise survey with the 

Secretary no later than 60 days after it installs the additional noise controls. 

29. Bayou Casotte Energy shall annually review its waterway suitability assessment for the project; 

update the assessment to reflect changing conditions; provide the updated assessment to the cognizant 

COTP/Federal Maritime Security Coordinator for review and validation; and provide a copy to the 

FERC staff. EIS Section 4.12.5

30. Bayou Casotte Energy shall provide the necessary information to demonstrate that the transient 

hazard areas identified in the final EIS are applicable prior to accepting ships greater than 140,000 

cubic meters in capacity. This information shall be filed with the Secretary for review and written 

approval of the Director of OEP. This information shall also be provided to the Coast Guard. EIS 

Section 4.12.5

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Recommendation numbers 31 through 71 shall apply to the LNG terminal design and 

construction details. Information pertaining to these specific recommendations shall be filed 

with the Secretary 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 recommendation. Items relating to 

Resource Report 13 - Engineering and Design Material and security should be submitted as 

critical energy infrastructure information pursuant to 18 CFR Parts 388.112 and PL01-1. 

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. Bayou Casotte Energy shall file this information a minimum of 30 

days before approval to proceed is required. 

31. Complete plan drawings and a list of the hazard detection equipment shall be filed prior to initial site 

preparation. The list shall include the instrument tag number, type and location, alarm locations, 

and shutdown functions of the proposed hazard detection equipment. Plan drawings shall clearly 

show the location of all detection equipment. EIS Section 4.12.2 

32. A technical review addressing the following information for the proposed facility should be filed 

prior to initial site preparation: 

a. Identification of all combustion/ventilation air intake equipment and the distances to any possible 

hydrocarbon release (LNG, flammable refrigerants, flammable liquids and flammable gases). 

b. A demonstration that these areas are adequately covered by hazard detection devices, including a 

description of how these devices would isolate or shutdown any combustion equipment whose 

continued operation could add to or sustain an emergency. EIS Section 4.12.2

33. Complete plan drawings and a list of the fixed and wheeled dry-chemical, fire extinguishing, and high 

expansion foam hazard control equipment shall be filed prior to initial site preparation. The list 

shall 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. EIS Section 4.12.2

34. 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 

shall be filed prior to initial site preparation. EIS Section 4.12.2

35. A copy of the hazard design review and list of recommendations that are to be incorporated in the 

final facility design shall be filed prior to initial site preparation. EIS Section 4.12.2

36. Drawings of the storage tank piping support structure and support of horizontal piping at grade shall 

be filed prior to initial site preparation. EIS Section 4.12.2

37. The P&IDs and design information for the NGL Recovery System shall be filed prior to initial site 

preparation. EIS Section 4.12.2

38. Procedures shall be developed for offsite contractors’ responsibilities, restrictions, limitations and 

supervision of these contractors by Bayou Casotte Energy staff, prior to initial site preparation. 

EIS Section 4.12.2

39. Bayou Casotte Energy shall develop emergency evacuation routes/methods for the areas along the 

route of the LNG carrier transit in conjunction with the local emergency planning groups and town 

officials and file the routes/methods with the Secretary for review and written approval by the 

Director or OEP prior to initial site preparation. EIS Section 4.12.5

40. Bayou Casotte Energy shall provide a comprehensive plan identifying the mechanisms for funding all 

project-specific security/emergency management costs that would be imposed on state and local 

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agencies. In addition to the funding of direct transit-related security/emergency management costs, 

this comprehensive plan shall include funding mechanisms for the capital costs associated with any 

necessary security/emergency management equipment and personnel base. This plan shall be filed 

with the Secretary prior to initial site preparation for review and approval by the Director of OEP. 

EIS Section 4.12.5

41. The final design of the hazard detection equipment shall identify manufacturer and model. EIS 

Section 4.12.2

42. The final design of the fixed and wheeled dry-chemical, fire extinguishing, and high expansion foam 

hazard control equipment should identify manufacturer and model. EIS Section 4.12.2

43. The final design shall include detailed drawings of the spill control system to be applied to the LNG 

tank roof. EIS Section 4.12.2

44. The final design shall specify that the LNG tank carbon steel piping support plates and connections 

to piping supports shall be designed to ensure that corrosion protection is adequately provided and 

provisions for corrosion monitoring and maintenance of carbon steel attachments are to be included in 

the design and maintenance procedures. EIS Section 4.12.2

45. The final design shall include details of the LNG tank tilt settlement and differential settlement limits 

between each LNG tank and piping and procedures to be implemented in the event that limits are 

exceeded. EIS Section 4.12.2

46. The final design shall include details of the pipe supports and restraints designed to prevent damage 

to piping systems and equipment in the event of a storm surge anticipated for a class 4 hurricane. EIS 

Section 4.12.2

47. The final design shall include provisions to install LNG transfer pumps at Jetty KO drum. EIS 

Section 4.12.2

48. The final design shall include details of the boiloff gas flow and temperature measurement for each 

tank. EIS Section 4.12.2

49. The final design shall include bypass valves around the intank discharge valves for cooldown of the 

24-inch headers and piping. EIS Section 4.12.2

50. The final design shall include an automatic shutoff valve in the LNG intermediate pump inlet line 

from the suction header. EIS Section 4.12.2

51. The final design shall include an automatic shutoff valve in the LNG sendout pump inlet line from 

the suction header. EIS Section 4.12.2

52. The final design shall include P&IDs and drawings of the meter station. 

53. The final design shall include a fire protection evaluation carried out in accordance with the 

requirements of NFPA 59A, chapter 9.1.2. EIS Section 4.12.2 

54. The final design shall include details of the shut down logic, including cause and effect matrices for 

alarms and shutdowns. EIS Section 4.12.2 

55. The final design shall include emergency shutdown of equipment and systems activated by hazard 

detection devices for flammable gas, fire, and cryogenic spills, when applicable. EIS Section 4.12.2 

56. The final design shall 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 shall vent to a safe location and be equipped with a leak detection 

device that: shall continuously monitor for the presence of a flammable fluid; shall alarm the 

hazardous condition; and shall shutdown the appropriate systems. EIS Section 4.12.2

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57. The final design shall include a HAZOP review of the completed design. A copy of the review and a 

list of the recommendations shall be filed. EIS Section 4.12.2

58. The P&IDs in the final design shall show and number all valves including drain, vent, main, and car 

sealed. EIS Section 4.12.2 

59. The final design shall include safeguards to be installed to protect above ground fire water piping, 

including post indicator valves, from inadvertent damage. EIS Section 4.12.2

60. The final design shall specify that all hazard detection equipment shall include redundancy and fault 

detection and fault alarm monitoring in all potentially hazardous areas and enclosures. EIS Section 

4.12.2

61. All valves including drain, vent, main, and car sealed valves shall be tagged in the field during 

construction and prior to commissioning. Instrumentation valves are excluded from this 

recommendation. EIS Section 4.12.2

62. 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 shall be filed prior to commissioning. EIS Section 

4.12.2 

63. A tabulated list of the proposed hand-held fire extinguishers shall be filed prior to commissioning. 

The information shall include a list with the equipment number, type, size, number, and location. 

Plan drawings shall include the type, size, and number of all hand-held fire extinguishers. EIS 

Section 4.12.2

64. Operation and maintenance procedures and manuals, as well as safety procedure manuals, shall be 

filed prior to commissioning. EIS Section 4.12.2

65. The contingency plan for failure of the LNG tank outer containment, approved by the tank 

manufacturer shall be filed prior to commissioning. EIS Section 4.12.2

66. A copy of the criteria for horizontal and rotational movement of the inner tank for use during and 

after cool down shall be filed prior to commissioning. EIS Section 4.12.2

67. The maintenance procedures to be filed prior to commissioning shall state that a foundation 

elevation survey of all LNG tanks shall be made on an annual basis. EIS Section 4.12.2

68. Bayou Casotte Energy shall coordinate with the Coast Guard to define the responsibilities of Bayou 

Casotte Energy’s security staff in supplementing other security personnel and in protecting the LNG 

tankers and terminal prior to commissioning. EIS Section 4.12.5

69. The FERC staff shall be notified of any proposed revisions to the security plan and physical security 

of the facility prior to commencement of service. EIS Section 4.12.2 

70. Bayou Casotte Energy shall develop an Emergency Response Plan (including evacuation) and 

coordinate procedures with local emergency planning groups, fire departments, state and local law 

enforcement, and appropriate Federal agencies. This plan shall 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; 

d. evacuation routes for public use areas and residents of areas along the route of the LNG transit; 

e. locations of permanent sirens and other warning devices; and 

f. an “emergency coordinator” on each LNG carrier to activate sirens and other warning devices. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
5-21

The Emergency Response Plan shall be filed with the Secretary for review and approval by the 

Director of OEP prior to commencement of service. Bayou Casotte Energy shall notify the FERC 

staff of all meetings in advance and shall report progress on its Emergency Response Plan at threemonth intervals starting at the commencement of construction. EIS Section 4.12.5

71. Progress on the construction of the LNG terminal shall be reported in monthly reports filed with the 

Secretary. Details shall include a summary of activities, projected schedule for completion, problems 

encountered and remedial actions taken. Problems of significant magnitude shall be reported to the 

FERC within 24 hours. EIS Section 4.12.2

Recommendation numbers 72 through 75 shall apply throughout the life of the facility: 

72. The facility shall 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, the Company shall 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 annual 

report, shall be filed. EIS Section 4.12.2

73. Semi-annual operational reports shall be filed with the Secretary to identify changes in facility 

design and operating conditions, abnormal operating experiences, activities (including ship arrivals, 

quantity and composition of imported LNG, vaporization quantities, boil-off/flash gas, etc.), plant 

modifications including future plans and progress thereof. Abnormalities shall 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 shall be reported. Reports shall be filed 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 shall 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. EIS Section 4.12.2

74. In the event the temperature of any region of any secondary containment, including imbedded pipe 

supports, becomes less than the minimum specified operating temperature for the material, the 

Commission shall be notified within 24 hours and procedures for corrective action shall be specified. 

EIS Section 4.12.2 

75. 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 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 shall be incorporated into the LNG facility's emergency plan. Examples of 

reportable LNG-related incidents include: 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
5-22

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. EIS Section 4.12.2

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX A 

FINAL EIS DISTRIBUTION LIST 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX A 

Final EIS Distribution List 

A-1

Federal Government Agencies

Advisory Council on Historic Preservation 

Director of Cultural Resources 

Office of Federal Agency Programs 

Laura Henley Dean 

Don L. Klima, Director 

Army Corps of Engineers 

Office of the Chief Army Engineers 

Corps of Engineers, Mobile District 

Colonel Peter F. Taylor, District Engineer 

David Schwartz 

Susan Rees 

Center for Disease Control 

Council on Environmental Quality 

Dina Bear, General Counsel 

Associate Director for NEPA Oversight 

Horst Greczmiel 

Department of Agricultural 

Natural Resources Conservation Service 

National Environmental Coordinator 

Homer L. Wilkes, Mississippi State Conservationist 

Department of the Army 

Office of the Asst. Secretary of the Army (Civil Works) 

Chip Smith, Asst. for Environment Tribal & Regulatory Affairs 

U.S. Forest Service 

Deputy Chief, National Forest System 

Director of Lands 

Ecosystem Management Coordination 

Department of the Air Force 

Office of Deputy Secretary Environment, Safety, and Occupational Health 

Department of Commerce 

National Oceanic and Atmospheric Administration 

Office of the Secretary 

Sloan Rappoport, Senior Policy Advisor 

National Marine Fisheries Service 

Office of Habitat Protection 

Karen Abrams, Marine Resources Habitat Specialist 

Protected Resources Division 

David Bernhart, Asst. Regional Administrator for Protected Species 

Miles Croom 

Kyle Baker 

Rick Ruebsamen 

Mark Thompson 

Department of Energy 

Robert Corbin, Manager 

Director for Import/Export Activities 

Harvey Harmon 

Office of Environmental Compliance 

Office of Intergovernmental Affairs 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX A (continued) 

Final EIS Distribution List 

A-2 

Federal Government Agencies (continued) 

Steve Lerner 

Office of the Secretary 

Department of Homeland Security 

 Unites States Coast Guard 

 Admiral Thomas H. Collins, Commandant 

 Ruth Ann Weidel 

Office of Operating and Environmental Standards 

 Captain David Scott 

 Coast Guard CEU Miami 

 Jon Mann 

 Coast Guard Sector Mobile 

 Captain Steven D. Hardy, Commanding Officer 

 LTJG Jonathan Mangum 

 Coast Guard Louisiana 

 Doug Blakemore 

Department of Housing and Urban Development 

 Director of Environment 

Department of Interior 

 Director of the Office of Environmental Policy and Compliance 

 Land and Minerals Managment 

 Patricia E. Morrison 

 Minerals Management Service 

 Walter Cruickshank, Deputy Director 

National Park Service 

U.S. Fish and Wildlife Service 

 Sam Hamilton, Regional Director 

 Paul Necaise 

 Daniel Gregg 

 Curtis James 

 National Park Service, Gulf Islands National Seashore, Mississippi Headquarters 

Department of Justice 

Land and Natural Resources Division 

Department of Labor 

Office of Regulatory Economics 

Department of Navy 

 Office of the Assistant Secretary of the Navy for Environment and Safety 

 Thomas Egeland 

 Office of Deputy Undersecretary Defense (Insatllations and Environment) 

 Patricia Ferrebee 

Office of the Assistant Secretary of the Navy (Installations and Environment) 

 Robert Uhrich 

 Operational Environmental Readiness & Planning 

 Karen Foskey, Environmental Planning/NEPA Lead 

 Assistant Chief of Staff for Installation Management 

 Paul E. Mason - ACSIM 

Department of State 

Office of the Undersecretary of State 

IRM 

 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX A (continued) 

Final EIS Distribution List 

A-3 

Federal Government Agencies (continued)

Office of the Under Secretary of Defence 

Philip Grone 

 Sonny White 

Office of Environment/Health 

Department of Transportation 

 Office of the Secreatary 

 Martin T. Whitmer, Jr., Asst. to the Secretary for Policy 

 Environmental Policies Team Leader 

 Camille Mittelholtz 

Office of Pipeline Safety 

Pipeline and Hazardous Materials Safety Administration 

Mike Schwarzkopf 

Karen Butler 

Tom Fortner 

William H. Gute, Director Eastern Region 

 Harold Winnie 

 Michael J. Khayata 

 John Pepper 

 John Jacobi 

Research & Special Programs Administrator 

Stacey Gerard, Associate Administrator 

James K. O'Steen, Deputy Associate Administrator 

 Community Assistance/Technical Services 

 Kimbra Davis 

DOT/RSPA/OHME/SW Region 

Operations Eastern Region 

 Alex Dankanich 

Environmental Protection Agency 

 Office of Federal Activities 

 Bob Hargrove, Director NEPA Compliance 

 Region 4 

 Gerald Miller 

 Katy Forney 

 Karrie-Jo Robinson-Shell 

Federal Energy Regulatory Commission 

Office of Energy Projects 

 Van Button 

John Leiss, Chief, Gas Branch 2 

J. Mark Robinson, Director 

Interstate Commerce Commission 

Chief Energy & Environment 

Library of Congress 

Exchange & Gift Division 

Federal Documents Section 

Senate 

Committee on Energy and Natural Gas 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX A (continued) 

Final EIS Distribution List 

A-4 

Federal Representatives and Senators 

Rep. Gene Taylor, 4th District 

Senator Trent Lott 

Senator Thad Cochran 

Mississippi State Legislature

Governor Haley Barbour 

Lt. Governor Amy Tuck 

Secretary of State’s Office 

Eric Clark, Secretary of State 

Margaret Anne Bretz, Public Lands 

Speaker of the Mississippi House of Representatives 

William J. McCoy 

Representative Billy Broomfield 

Representative Danny Guice, Jr. 

Representative Frank Hamilton 

Representative Deryk Parker 

Representative John O. Read 

Representative Carmel Weels Smith 

Representative H.B. “Hank” Zuber III 

Senator Ezell Lee 

Senator Tommy Moffatt 

Senator Thomas E. Robertson 

State Government Agencies

Mississippi Department of Agriculture 

 Lester Spell, Jr., Commissioner 

Mississippi Department of Environmental Quality 

Charles Chisolm, Executive Director 

James R. Carter, Chairman 

Coastal Impact Assistance Program 

 Robbie Wilbur, Coordinator 

Office of Land and Water Resources 

 Sam Mabry, Director 

Office of Pollution Control 

 Phil Bass, Director 

 Mayo Rao, Chief Energy Transportation Branch 

 Jerry Cain 

 Robert Seyfarth 

Mississippi Department of Health 

 Brian W. Amy 

Mississippi Department of Marine Resources 

 Jerry Brashier, Director of Regulatory Functions 

 Jan Boyd 

 Shelby Drummond 

 Dale Diaz 

 Mike Walker 

 Joe Ziegler 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX A (continued) 

Final EIS Distribution List 

A-5 

State Government Agencies (continued)

Mississippi Department of Wildlife Fisheries and Parks 

 Dr. Sam Polles, Executive Director 

 Bubba Hubbard 

Mississippi Division of Tourism 

Mississippi Forestry Commission 

 Brad Stevens, Chairman 

Mississippi Library Commission 

 Sharman B. Smith, Director 

Mississippi Museum of Natural Science – Natural Heritage Program 

 Bill Johnson 

 Tom Mann 

Mississippi Oil and Gas Board 

 Walter Boone, Jr., Supervisor 

Mississippi State Port Authority 

 Donald R. Allee, Executive Director 

State Fire Marshals Office 

 George Dale 

State Historic Preservation Office 

 Tom Waggoner 

Local Government Agencies

Jackson County Board of Supervisors 

 Manly Barton, President 

 Alan Suddoth 

Jackson County Historical Society 

Jackson County Planning Commission 

 Michelle Bishop, Director 

Jackson County Port Authority 

 Allen Moeller, Assistant Port Director 

 Warren Gautier 

 Jim Hoskins 

Jackson County Sheriff 

 Mike Byrd 

Jackson County Water Quality Task Force 

 Randy Meador, Program Manager 

City of Pascagoula 

 Joe D. Cole, Jr., Mayor 

 Michael W. Mangum, Councilman 

 Melvin Mitchell, City Attorney 

 Mike Whitmore, Police Chief 

 Keith and Anita Belcher 

 Dave Crenshaw 

 Bebe Sutherland 

Pascagoula Parks and Recreation Department 

Darcie Shortt, Director 

Pascagoula School District 

 Wayne Rodolfich, Superintendent 

 Mike Concannon, Board Member 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX A (continued) 

Final EIS Distribution List 

A-6 

 Dick Paul, Board Member 

Port of Pascagoula 

 Mark L. McAndrews, Director 

Bayou Casotte Fire Station 

Libraries

Jackson-George Regional Library System 

Media

Mississippi Press 

The Sun Herald 

WLOX-TV 

Native American Tribes

Mississippi Band of Choctaw Indians 

Phillip Martin, Chief 

Ken Carlton, THPO 

Jena Band of Choctaw Indians 

 Christine Norris, Tribal Council Member 

Choctaw Nation of Oklahoma 

 Terry Cole, THPO 

Tunica-Biloxi Indians 

Earl J. Barbry, Sr., Chairman 

Intervenors

ExxonMobil Gas & Power Marketing Company 

 DeMonica D. Gladney 

 John W. Poe 

 Kevin M. Sweeny, Attonery, John & Hengerer 

Florida Gas Transmission Company 

 Michael T. Langston, Senior Vice President 

 Frazier King, Senior Counsel 

Gulf LNG Energy, LLC 

 L. Wayne Christian 

 John M. McCutchen 

 Joseph W. Peacock 

 Tania S. Perez, Attonery, King & Spalding LLP 

 Erick J.A. Swenson, Attonery, King & Spalding LLP 

Seminole Electric Cooperative, Inc. 

 Jack Reid, Director of Fuel Supply 

James H. Byrd, Attonery, Miller, Balis & O’Neil, PC 

Sempra Energy 

 William Rapp, Senior Regulatory Counsel 

 Stacy Van Goor, Director Federal Regulatory Affairs 

Southern Natural Gas Company 

 Patrick B. Pope, Vice President 

 James D. Johnston, Senior Council 

Transcontinental Gas Pipe Line Corporation 

 Stephen A. Hatridge, Senior Counsel 

 Jan Roberts, Marketing Services Consultant 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX A (continued) 

Final EIS Distribution List 

A-7 

Organizations 

American Gas Association 

 Dave Parker 

Amoco Production Company 

Bank of Lucedale 

 John J. Whitehead 

Bar Pilot 

Walter Gautier 

Bayou Casotte Energy LLC 

Richard A. Lammons 

Central Fire Station (Pascagoula) 

Chevron Texaco 

 Duane Chisholm 

 Mike De Nicola 

Chevron USA Inc (Corning Lease) 

Coastal Conservation Association Mississippi 

 Ronald Emmons 

Coast Valve & Fittings Co Inc 

Consolidated Pipe & Supply Co 

CVX Pascagoula 

Randy Thweatt 

Dantzler Mgt LLC 

 Carol Watson 

 Kerri Neal 

Destin Pipeline Company LLC 

 Bruce Reed 

 Moss Point Office 

ENSR 

 David Heinold 

 Heather Spivey 

 Keith Suderman 

ENTRIX, Inc. 

 Erik Dilts 

 Trevor Loveday 

Escatawpa Volunteer Fire Department 

Estabrook Properties LP 

First Chemical 

 Steve Dawson 

 Laura Wood 

Gulf Regional Planning Commission 

 Elaine Wilkinson 

Gulf States Marine Fisheries Commission 

 Larry B. Simpson 

 Jeff Rester 

Hardy/Jacobson 

 Harris Hardy 

 Len Jacobson 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX A (continued) 

Final EIS Distribution List 

A-8 

Organizations (continued) 

IBEW 

 James Duhon 

 Thomas Murphy 

 Timothy Overmier 

Jackson County Chamber of Commerce 

 Nicole Yuratich 

Jackson County Economic Development Foundation Inc. 

 George L. Freeland Jr. 

Jerry Lee Family Limited Partnership 

Jones Day 

 Jason Leif 

L & L Investments Ltd 

Lake Avenue Fire Station (Pascagoula) 

Manning Trucking Inc. 

Marvin Mostellar Trustee 

Miller Contracting LLC 

Mississippi Chapter Sierra Club 

 Becky Gillette 

 Rose Johnson 

Mississippi Coast Audubon Society 

 Charlie Brenke 

Mississippi Phosphates Corporation 

Nature Conservancy Mississippi Field Office 

 Robbie Fisher 

Natural Resources Group, Inc., (Minneapolis) 

 Jennifer Lee 

 Pat Terhaar 

Panhandle Energy 

 Brian Essner 

 Keith Riebe 

Pascagoula School District 

 Charlotte & Jerry Clement 

Phillips & Jordan 

 David Buchanan 

Pipeline Contractors Association 

 J Patrick Tielborg 

PLATTS 

 Christine Valentine 

Rocky Mountain P/L Construction Association 

 J.D. Lormand – Executive Director 

Sierra Club Gulf Coast Group 

 Brenda Songy 

Singing River Electric Power Association 

Soil and Water Conservation Commission 

 Kathy Hamrick 

State Farm Insurance 

 Don & Dena McKee 

Stringfellow Family Trust 

 Nancy Mabel 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX A (continued) 

Final EIS Distribution List 

A-9 

T C Broome Construction Co LLC 

The Nature Conservancy 

 Cynthia Ramseur 

The Wilderness Society 

 Pete Morton Ph.D. 

Organizations (continued) 

The Williams Co 

TRC Environmental 

 Brad Floyd 

 Dave Jenkins 

 JH Rumpp 

US Joiner LLC+A250 

West Jackson County Fire Station (Biloxi) 

Individuals

Donald Frank & Pamela Moss Andrews 

Jonice Baggett 

Spencer L. Bailey 

W. Michael Barry 

Janie Baugh 

Mary Blackwell 

Michelle Blevins 

Clyde S. Bosarge 

Julius Bosco 

George Andrew & Gertrud Branam 

Tim Broussard 

Joanne Caffrey 

John Carey 

Sergio Coletta 

Robert L. & Rhonda Kay Delmas 

Shirley Ann Delmas 

J. S. Delmas Jr. 

Oscar Eckhoff 

Thomas E. Eselin 

Randolph F. & Joedna Fagan 

J.M. Ford 

Liz Ford 

Rob Ford 

Michael Foster 

Peter D. Guidry Sr. 

James N. Haas III 

Gary W. Hall 

Virginia Sue Hall & Heidelberg H. P. Jacobson Jr. 

Hancock Bank 

Michael C Holly 

Peggy Hoover 

Thomas J. Jackson 

Bird Johnson 

Harry Johnson 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX A (continued) 

Final EIS Distribution List 

A-10 

Individuals (continued)

Brett Keenan 

Sidney M. & Martha Sue Kibby 

Brian Keith & David Earl Knight 

Pat Kulick 

Linda Tyler Lee 

James E. Lennep 

Rick Looser 

Darryl Malek-Wiley 

Mac McInnis 

David McKey 

Mary Mullins 

Christopher Murray 

Gene & Kathleen Patterson 

Albert Pettigrew 

Jack Pickering & Selina Breland 

Jessie Ellen Portas 

Syliva Posey 

Steve Renfroe 

Donna Ritchey 

Bennie A Rohr 

B. Sachau 

Alvin C. & Sylvia Ann Sherrell 

Tom Singley 

Cheryl J. Smith 

Douglas D. & Donna L Stork 

John Surratt 

Muriel Swint 

Gerald W. Taylor 

John Thomas 

Benjamin E & Adele H Tillman 

Lorene & Irby Tillman 

Paula Vassey 

William L. & Mary Louise Ware 

A J & Deann M Whitehead 

Phillip Whitehead 

Ronald P. Williams 

Charles & Betty Wolverton 

George Wolverton 

Charles M Wright 

Rhonda Yoder 

Residences and Businesses within 1.0 Mile of the Proposed Project - Privileged and 

Confidential Information - Not for Release

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX B1 

BAYOU CASOTTE ENERGY’S PLAN 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Bayou Casotte Plan 1 September 2005 

BAYOU CASOTTE ENERGY’S 

UPLAND EROSION CONTROL, REVEGETATION, AND 

MAINTENANCE PLAN 

JUNE 2005 

Introduction 

Bayou Casotte Energy LLC, (Bayou Casotte Energy), has developed the following 

guidelines to be used during the construction of the Casotte Landing Natural Gas Import 

Terminal Project (Project) proposed near Pascagoula in Jackson County, Mississippi. 

This document has been created in conjunction and is consistent with the Federal 

Energy Regulatory Commission (FERC) Office of Energy Projects (OEP) construction, 

restoration and maintenance guidelines commonly referred to as the Upland Erosion 

Control, Revegetation and Maintenance Plan (Plan), 1/17/2003 Version. 

Bayou Casotte Energy has reviewed the FERC Plan and has determined that adoption 

of the Plan to address erosion and sedimentation control and environmental construction 

issues that may be encountered on the Project. 

Bayou Casotte Energy is committed to assuring the necessary efforts are undertaken for 

each newly proposed project to review and verify that all requirements and/or guidelines 

are applicable and can be complied with during construction and operational 

maintenance of a project. 

In the event Bayou Casotte Energy is unable to comply and/or accept the guidelines set 

out in the FERC Plan, variances will be requested from the specific guideline or 

requirement with full justification for the requested variance offering equal or better 

protection for the protected resource. 

This document is a preliminary document, which will be further modified based on site 

specific conditions or requests made and agreed to by Bayou Casotte Energy and 

respective landowners, permitting agencies and/or other regulatory agencies with 

jurisdictional authority over resources that may be impacted by the construction of this 

Project. Figures will be added to this document for clarification and utilization during the 

construction phase of the proposed Project. 

Bayou Casotte Energy has identified and is requesting several variances to the FERC 

Plan, which are outlined in the following.

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
LIST OF FIGURES 

Bayou Casotte Plan 1 September 2005 

LIST OF FIGURES 

 No. Description 

Plan-1 Typical Pipeline Construction Sequence 

Plan-2 Typical Construction Right-of-Way Cross Section (as necessary) 

Plan-3 Permanent Water Bars or Terraces 

Plan-4 Silt Fence Installation 

Plan-5 Typical Hay/Straw Bale Installation 

Plan-6 Typical Trench Breakers 

Plan-7 Typical Rock Construction Entrance 

Plan-8 Typical Erosion Control Fabric 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
PLAN 

Bayou Casotte Plan 2 September 2005 

BAYOU CASOTTE ENERGY’S UPLAND EROSION CONTROL, 

REVEGETATION, AND MAINTENANCE PLAN 

TABLE OF CONTENTS 

I. APPLICABILITY ...............................................................................................................................................1

II. SUPERVISION AND INSPECTION.............................................................................................................2

A. ENVIRONMENTAL INSPECTION.............................................................................................................2

B. RESPONSIBILITIES OF ENVIRONMENTAL INSPECTORS...................................................................2

III. PRECONSTRUCTION PLANNING.............................................................................................................4

A. CONSTRUCTION WORK AREAS..............................................................................................................4

B. DRAIN TILE AND IRRIGATION SYSTEMS .............................................................................................4

C. GRAZING DEFERMENT.............................................................................................................................4

D. ROAD CROSSINGS AND ACCESS POINTS .............................................................................................4

E. DISPOSAL PLANNING ...............................................................................................................................5

F. AGENCY COORDINATION .......................................................................................................................5

G. STORMWATER POLLUTION PREVENTION PLAN ...............................................................................5

IV. INSTALLATION.............................................................................................................................................5

A. APPROVED AREAS OF DISTURBANCE..................................................................................................5

B. TOPSOIL SEGREGATION ..........................................................................................................................6

C. DRAIN TILES...............................................................................................................................................7

D. IRRIGATION................................................................................................................................................7

E. ROAD CROSSINGS AND ACCESS POINTS .............................................................................................8

F. TEMPORARY EROSION CONTROL .........................................................................................................8

1. Temporary Slope Breakers ............................................................................................................................8

2. Sediment Barriers ..........................................................................................................................................9

3. Mulch.............................................................................................................................................................9

V. RESTORATION............................................................................................................................................10

A. CLEANUP...................................................................................................................................................10

B. PERMANENT EROSION CONTROL DEVICES......................................................................................11

1. Trench Breakers ..........................................................................................................................................11

2. Permanent Slope Breakers...........................................................................................................................12

C. SOIL COMPACTION MITIGATION.........................................................................................................12

D. REVEGETATION.......................................................................................................................................13

1. General ........................................................................................................................................................13

2. Soil Additives (for those Project areas utilized via an easement agreement only) ......................................13

3. Seeding Requirements (for those Project areas utilized via an easement agreement only).........................13

VI. OFF-ROAD VEHICLE CONTROL............................................................................................................14

VII. POST-CONSTRUCTION ACTIVITIES.....................................................................................................15

A. MONITORING AND MAINTENANCE ....................................................................................................15

B. REPORTING...............................................................................................................................................16

VARIANCE DETAILED DISCUSSION.................................................................................................................17

FIGURES ...................................................................................................................................................................22

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
PLAN 

Bayou Casotte Plan 1 September 2005 

UPLAND EROSION CONTROL, REVEGETATION, 

AND MAINTENANCE PLAN (PLAN)

Construction activities associated with Casotte Landing are both similar to, and different from, 

typical construction activities related to natural gas facilities, particularly as they apply to Project 

areas that are owned in fee versus utilized via an easement agreement. The similarities are in that 

the same environmental construction standards and Best Management Practices will be employed 

regardless of an area being owned in fee or “borrowed” via an easement agreement. There are also 

differences in that those Project areas owned in fee may not necessarily require all of the measures 

outlined in this document. Ultimate care must be used when distinguishing between these Project 

areas on the approved Project plans as different restoration/mitigation measures will be applied 

dependent upon the area in question. 

I. APPLICABILITY 

A. The intent of this Plan is to assist applicants by identifying baseline mitigation 

measures for minimizing erosion and enhancing revegetation. The project sponsors 

should specify in their applications for a FERC Certificate (Certificate) any 

individual measures in this Plan they consider unnecessary, technically infeasible, or 

unsuitable due to local conditions and to fully describe any alternative measures they 

would use. Applicants should also explain how those alternative measures would 

achieve a comparable level of mitigation. 

 Bayou Casotte Energy has prepared variances to portions of this Plan and noted 

them in the text (bold, italicized text). Detailed discussions associated with these 

variances are attached to the end of this plan. 

Once a project is certificated, further changes can be approved. Any such changes 

from the measures in this Plan (or the applicant’s approved plan) will be approved by 

the Director of the Office of Energy Projects (Director), upon the applicant’s written 

request, if the Director agrees that an alternative measure: 

1. provides equal or better environmental protection; 

2. is necessary because a portion of this Plan is infeasible or unworkable based 

on project-specific conditions; or 

3. is specifically required in writing by another Federal, state, or Native 

American land management agency for the portion of the project on its land 

or under its jurisdiction. 

Any requirements in this Plan to file material with the Secretary of the FERC 

(Secretary) do not apply to projects undertaken under the provisions of the blanket 

certificate program. This exemption does not apply to a request for alternative 

measures. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
PLAN 

Bayou Casotte Plan 2 September 2005 

Project-related impacts on wetland and waterbody systems are addressed in the 

staff’s Wetland and Waterbody Construction and Mitigation Procedures 

(Procedures). 

II. SUPERVISION AND INSPECTION 

A. ENVIRONMENTAL INSPECTION 

1. At least one Environmental Inspector is required for each construction spread 

(a “spread” is defined herein as both the Terminal and the Natural Gas 

System Interconnections) during construction and restoration (as defined by 

section V). The number and experience of Environmental Inspectors 

assigned to each construction spread should be appropriate for the length of 

the construction spread and the number/significance of resources affected. 

2. Environmental Inspectors shall have peer status with all other activity 

inspectors. 

3. Environmental Inspectors shall have the authority to stop activities that 

violate the environmental conditions of the Certificate, state and Federal 

environmental permit conditions, or landowner requirements; and to order 

appropriate corrective action. 

B. RESPONSIBILITIES OF ENVIRONMENTAL INSPECTORS 

At a minimum, the Environmental Inspector(s) shall be responsible for: 

1. Ensuring compliance with the requirements of this Plan, the Procedures, the 

environmental conditions of the Certificate authorization, the mitigation 

measures proposed by the applicant (as approved and/or modified by the 

Certificate), other environmental permits and approvals, and environmental 

requirements in landowner easement agreements; 

2. Identifying, documenting, and overseeing corrective actions, as necessary to 

bring an activity back into compliance; 

3. Verifying that the limits of authorized construction work areas and locations 

of access roads are properly marked before clearing; 

4. Verifying the location of signs and highly visible flagging marking the 

boundaries of sensitive resource areas, waterbodies, wetlands, or areas with 

special requirements along the construction work area; 

5. Identifying erosion/sediment control and soil stabilization needs in all areas; 

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Bayou Casotte Plan 3 September 2005 

6. Ensuring that the location of dewatering structures and slope breakers will 

not direct water into known cultural resources sites or locations of sensitive 

species; 

7. Verifying that trench dewatering activities do not result in the deposition of 

sand, silt, and/or sediment near the point of discharge into a wetland or 

waterbody. If such deposition is occurring, the dewatering activity shall be 

stopped and the design of the discharge shall be changed to prevent 

reoccurrence; 

8. Ensuring that subsoil and topsoil are tested in agricultural and residential 

areas to measure compaction and determine the need for corrective action; 

9. Advising the Chief Construction Inspector when conditions (such as wet 

weather) make it advisable to restrict construction activities to avoid 

excessive rutting; 

10. Ensuring restoration of contours and topsoil; 

11. Verifying that the soils imported for agricultural or residential use have been 

certified as free of noxious weeds and soil pests, unless otherwise approved 

by the landowner; 

12. Determining the need for and ensuring that erosion controls are properly 

installed, as necessary to prevent sediment flow into wetlands, waterbodies, 

sensitive areas, and onto roads; 

13. Inspecting and ensuring the maintenance of temporary erosion control 

measures at least: 

a. on a daily basis in areas of active construction or equipment 

operation; 

b. on a weekly basis in areas with no construction or equipment 

operation; and 

c. within 24 hours of each 0.5 inch of rainfall; 

14. Ensuring the repair of all ineffective temporary erosion control measures 

within 24 hours of identification; 

15. Keeping records of compliance with the environmental conditions of the 

FERC certificate, and the mitigation measures proposed by the project 

sponsor in the application submitted to the FERC, and other Federal or state 

environmental permits during active construction and restoration; and 

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Bayou Casotte Plan 4 September 2005 

16. Identifying areas that should be given special attention to ensure stabilization 

and restoration after the construction phase. 

III. PRECONSTRUCTION PLANNING 

The project sponsor shall do the following before construction: 

A. CONSTRUCTION WORK AREAS 

1. Identify all construction work areas (e.g., construction right-of-way, extra 

work space areas, pipe storage and contractor yards, borrow and disposal 

areas, access roads, etc.) that would be needed for safe construction. The 

project sponsor must ensure that appropriate cultural resources and biological 

surveys have been conducted. 

2. Project sponsors are encouraged to consider expanding any required cultural 

resources and endangered species surveys in anticipation of the need for 

activities outside of certificated work areas. 

B. DRAIN TILE AND IRRIGATION SYSTEMS 

1. Attempt to locate existing drain tiles and irrigation systems. 

2. Contact landowners and local soil conservation authorities to determine the 

locations of future drain tiles that are likely to be installed within 3 years of 

the authorized construction. 

3. Develop procedures for constructing through drain-tiled areas, maintaining 

irrigation systems during construction, and repairing drain tiles and irrigation 

systems after construction. 

4. Engage qualified drain tile specialists, as needed to conduct or monitor 

repairs to drain tile systems affected by construction. Use drain tile 

specialists from the project area, if available. 

C. GRAZING DEFERMENT 

Develop grazing deferment plans with willing landowners, grazing permittees, and 

land management agencies to minimize grazing disturbance of revegetation efforts. 

D. ROAD CROSSINGS AND ACCESS POINTS 

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Bayou Casotte Plan 5 September 2005 

Plan for safe and accessible conditions at all roadway crossings and access points 

during construction and restoration. 

E. DISPOSAL PLANNING 

Determine methods and locations for the disposal of construction debris (e.g., timber, 

slash, mats, garbage, drilling fluids, excess rock, etc). Off-site disposal in other than 

commercially operated disposal locations is subject to compliance with all applicable 

survey, landowner permission, and mitigation requirements. 

F. AGENCY COORDINATION 

The project sponsor must coordinate with the appropriate local, state, and Federal 

agencies as outlined in this Plan and in the Certificate. 

1. Obtain written recommendations from the local soil conservation authorities 

or land management agencies regarding permanent erosion control and 

revegetation specifications for those Project areas utilized via an easement 

agreement only. 

2. Develop specific procedures in coordination with the appropriate agency to 

prevent the introduction or spread of noxious weeds and soil pests resulting 

from construction and restoration activities for those Project areas utilized 

via an easement agreement only. 

G. STORMWATER POLLUTION PREVENTION PLAN 

Make available on each construction spread the Stormwater Pollution Prevention 

Plan prepared for compliance with the U.S. Environmental Protection Agency's 

National Stormwater Program General Permit requirements. 

IV. INSTALLATION 

A. APPROVED AREAS OF DISTURBANCE 

1. Project-related ground disturbance shall be limited to the construction rightof-way, extra work space areas, pipe storage yards, borrow and disposal 

areas, access roads, and other areas approved in the Certificate. Any projectDocument Accession #: 20061222-4000 Filed Date: 12/22/2006
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Bayou Casotte Plan 6 September 2005 

related ground disturbing activities outside these Certificated areas, except 

those needed to comply with the Plan and Procedures (e.g., slope breakers, 

energy-dissipating devices, dewatering structures, drain tile system repairs) 

will require prior Director approval. All construction or restoration activities 

outside of the Certificated areas are subject to all applicable survey and 

mitigation requirements. 

2. The construction right-of-way width for a project shall not exceed 75 feet or 

that described in the FERC application unless otherwise modified by a 

Certificate condition. However, in limited, non-wetland areas, this 

construction right-of-way width may be expanded by up to 25 feet without 

Director approval to accommodate full construction right-of-way topsoil 

segregation and to ensure safe construction where topographic conditions 

(such as side-slopes) or soil limitations require it. Twenty-five feet of extra 

construction right-of-way width may also be used in limited, non-wetland or 

non-forested areas for truck turn-arounds where no reasonable alternative 

access exists. Bayou Casotte Energy is proposing a nominal construction 

right-of-way of 110 feet in several locations along the pipeline route. The 

soils expected along the pipeline route are predominately poorly drained 

mucky sandy clay loam that is frequently flooded. Moreover, the water 

table is typically very close to the surface. These conditions will adversely 

affect the slope and stability of the excavation and indicate greater than 

normal excavation (ditch) widths and spoil volume. In addition to these 

complications, an expanded construction right-of-way is needed due to the 

containment of a dual pipeline configuration.

Project use of these additional limited areas is subject to landowner approval 

and compliance with all applicable survey and mitigation requirements. 

When such additional areas are used, each one should be identified and the 

need explained in the weekly or biweekly construction reports to the FERC, 

if required. The following material should be included in the reports: 

a. the location of each additional area by station number and reference to 

a previously filed alignment sheet, or updated alignment sheets 

showing the additional areas; 

b. identification of where the Commission's records contain evidence 

that the additional areas were previously surveyed; and 

c. a statement that landowner approval has been obtained and is 

available in project files. 

Prior written approval of the Director is required when the Certificated 

construction right-of-way width would be expanded by more than 25 feet. 

B. TOPSOIL SEGREGATION 

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Bayou Casotte Plan 7 September 2005 

1. Unless the landowner or land management agency specifically approves 

otherwise, prevent the mixing of topsoil with subsoil by stripping topsoil 

from the trench and subsoil storage area (ditch plus spoil side method in) or 

as requested by a landowner for those Project areas utilized via an 

easement agreement only: 

a. actively cultivated or rotated croplands and pastures; 

b. residential areas; 

 

c. hayfields; and 

d. other areas at the landowner's or land managing agency’s request. 

 

2. In residential areas importation of topsoil is an acceptable alternative to 

topsoil segregation. 

3. In deep soils (more than 12 inches of topsoil), segregate at least 12 inches of 

topsoil. In soils with less than 12 inches of topsoil make every effort to 

segregate the entire topsoil layer. 

4. Where topsoil segregation is required, maintain separation of salvaged topsoil 

and subsoil throughout all construction activities. 

5. Segregated topsoil may not be used for padding the pipe. 

C. DRAIN TILES 

1. Mark locations of drain tiles damaged during construction. 

2. Probe all drainage tile systems within the area of disturbance to check for 

damage. 

3. Repair damaged drain tiles to their original or better condition. Do not use 

filter-covered drain tiles unless the local soil conservation authorities and the 

landowner agree. Use qualified specialists for testing and repairs. 

4. For new pipelines in areas where drain tiles exist or are planned, ensure that 

the depth of cover over the pipeline is sufficient to avoid interference with 

drain tile systems. For adjacent pipeline loops in agricultural areas, install 

the new pipeline with at least the same depth of cover as the existing 

pipeline(s). 

D. IRRIGATION 

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Bayou Casotte Plan 8 September 2005 

Maintain water flow in crop irrigation systems, unless shutoff is coordinated with 

affected parties. 

E. ROAD CROSSINGS AND ACCESS POINTS 

1. Maintain safe and accessible conditions at all road crossings and access 

points during construction. 

2. If crushed stone access pads are used in residential or active agricultural 

areas, place the stone on synthetic fabric to facilitate removal. 

F. TEMPORARY EROSION CONTROL 

Install temporary erosion controls immediately after initial disturbance of the soil. 

Temporary erosion controls must be properly maintained throughout construction 

(on a daily basis) and reinstalled as necessary (such as after backfilling of the trench) 

until replaced by permanent erosion controls or restoration is complete. 

1. Temporary Slope Breakers 

a. Temporary slope breakers are intended to reduce runoff velocity and 

divert water off the construction right-of-way. Temporary slope 

breakers may be constructed of materials such as soil, silt fence, 

staked hay or straw bales, or sand bags. 

b. Install temporary slope breakers on all disturbed areas, as necessary to 

avoid excessive erosion. Temporary slope breakers must be installed 

on slopes greater than 5 percent where the base of the slope is less 

than 50 feet from waterbody, wetland, and road crossings at the 

following spacing (closer spacing should be used if necessary): 

 Slope (%) Spacing (feet)

 5 - 15 300 

 >15 - 30 200 

 >30 100 

c. Direct the outfall of each temporary slope breaker to a stable, well

vegetated area or construct an energy-dissipating device at the end 

of the slope breaker and off the construction right-of-way. Extend 

each temporary slope breaker marginally off the disturbed right-ofway so that the outfall exits onto a stable, well vegetated area. If a 

stable, well vegetated area does not exist, construct an energy 

dissipater at the end of the slope breaker. These structures will not 

adversely affect sensitive environmental areas.

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Bayou Casotte Plan 9 September 2005 

d. Position the outfall of each temporary slope breaker to prevent 

sediment discharge into wetlands, waterbodies, or other sensitive 

resources. 

2. Sediment Barriers 

a. Sediment barriers are intended to stop the flow of sediments and to 

prevent the deposition of sediments into sensitive resources. They 

may be constructed of materials such as silt fence, staked hay or straw 

bales, compacted earth (e.g., drivable berms across travelways), sand 

bags, or other appropriate materials. 

b. At a minimum, install and maintain temporary sediment barriers 

across the entire construction right-of-way at the base of slopes 

greater than 5 percent where the base of the slope is less than 50 feet 

from a waterbody, wetland, or road crossing until revegetation is 

successful as defined in this Plan. Leave adequate room between the 

base of the slope and the sediment barrier to accommodate ponding of 

water and sediment deposition. 

c. Where wetlands or waterbodies are adjacent to and downslope of 

construction work areas, install sediment barriers along the edge of 

these areas, as necessary to prevent sediment flow into the wetland or 

waterbody. 

d. Small openings will be left in the sediment barriers to allow 

temporary and permanent slope breakers to exit the certificated 

right-of-way. 

3. Mulch 

a. Apply mulch on all slopes (except in actively cultivated cropland) 

concurrent with or immediately after seeding, where necessary to 

stabilize the soil surface and to reduce wind and water erosion. 

Spread mulch uniformly over the area to cover at least 75 percent of 

the ground surface at a rate of 2 tons/acre of straw or its equivalent, 

unless the local soil conservation authority, landowner, or land 

managing agency approves otherwise in writing. 

b. Mulch can consist of weed-free straw or hay, wood fiber hydromulch, 

erosion control fabric, or some functional equivalent. 

c. Mulch before seeding in those Project areas utilized via an easement 

agreement only if: 

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Bayou Casotte Plan 10 September 2005 

(1) final grading and installation of permanent erosion control 

measures will not be completed in an area within 20 days after 

the trench in that area is backfilled (10 days in residential 

areas), as required in section V.A.1; or 

(2) construction or restoration activity is interrupted for extended 

periods, such as when seeding cannot be completed due to 

seeding period restrictions. 

d. If mulching before seeding, increase mulch application on all slopes 

within 100 feet of waterbodies and wetlands to a rate of 3 tons/acre of 

straw or equivalent. 

e. If wood chips are used as mulch, do not use more than 1 ton/acre and 

add the equivalent of 11 lbs/acre available nitrogen (at least 50 percent 

of which is slow release). 

f. Ensure that mulch is adequately anchored to minimize loss due to 

wind and water. 

g. When anchoring with liquid mulch binders, use rates recommended 

by the manufacturer. Do not use liquid mulch binders within 100 feet 

of wetlands or waterbodies. 

h. Install erosion control fabric on waterbody banks at the time of final 

bank recontouring. Anchor the erosion control fabric with staples or 

other appropriate devices. 

V. RESTORATION 

A. CLEANUP 

1. Commence cleanup operations immediately following backfill operations in 

those Project areas utilized via an easement agreement only. Complete final 

grading, topsoil replacement, and installation of permanent erosion control 

structures within 20 days after backfilling the trench (10 days in residential 

areas). If seasonal or other weather conditions prevent compliance with these 

time frames, maintain temporary erosion controls (temporary slope breakers 

and sediment barriers) until conditions allow completion of cleanup. 

The project sponsor should file with the Secretary for the review and written 

approval of the Director, a winterization plan if construction will continue 

into the winter season when conditions could delay successful decompaction, 

topsoil replacement, or seeding until the following spring. 

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Bayou Casotte Plan 11 September 2005 

2. A travel lane may be left open temporarily to allow access by construction 

traffic if the temporary erosion control structures are installed (as specified in 

section IV.F.) and inspected and maintained (as specified in sections II.B.12 

through 14). When access is no longer required, the travel lane must be 

removed and the right-of-way restored. 

3. Rock excavated from the trench may be used to backfill the trench only to the 

top of the existing bedrock profile. Rock that is not returned to the trench 

should be considered construction debris, unless approved for use as mulch or 

for some other use on the construction work areas by the landowner or land 

managing agency. 

4. Remove excess rock from at least the top 12 inches of soil in all actively 

cultivated or rotated cropland and pastures, hayfields, and residential areas, as 

well as other areas at the landowner's request. The size, density, and 

distribution of rock on the construction work area should be similar to 

adjacent areas not disturbed by construction. The landowner may approve 

other provisions in writing. 

5. Grade the construction right-of-way in those Project areas utilized via an 

easement agreement only to restore pre-construction contours and leave the 

soil in the proper condition for planting. 

6. Remove construction debris from all construction work areas unless the 

landowner or land managing agency approves otherwise. 

7. Remove temporary sediment barriers when replaced by permanent erosion 

control measures or when revegetation is successful. 

B. PERMANENT EROSION CONTROL DEVICES 

1. Trench Breakers 

a. Trench breakers are intended to slow the flow of subsurface water 

along the trench. Trench breakers may be constructed of materials 

such as sand bags or polyurethane foam. Do not use topsoil in trench 

breakers. 

b. An engineer or similarly qualified professional shall determine the 

need for and spacing of trench breakers. Otherwise, trench breakers 

shall be installed at the same spacing as and upslope of permanent 

slope breakers. 

c. In agricultural fields and residential areas where slope breakers are not 

typically required, install trench breakers at the same spacing as if 

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Bayou Casotte Plan 12 September 2005 

permanent slope breakers were required or as directed by an engineer 

or similarly qualified professional. 

d. At a minimum, install a trench breaker at the base of slopes greater 

than 5 percent where the base of the slope is less than 50 feet from a 

waterbody or wetland and where needed to avoid draining a 

waterbody or wetland or as directed by an engineer or similarly 

qualified professional.

2. Permanent Slope Breakers 

a. Permanent slope breakers are intended to reduce runoff velocity, 

divert water off the construction right-of-way, and prevent sediment 

deposition into sensitive resources. Permanent slope breakers may be 

constructed of materials such as soil, sand bags, or some functional 

equivalent. 

b. Construct and maintain permanent slope breakers in all areas, except 

cultivated areas and lawns, using spacing recommendations obtained 

from the local soil conservation authority or land managing agency. 

In the absence of written recommendations, use the following spacing 

unless closer spacing is necessary to avoid excessive erosion on the 

construction right-of-way: 

 

 

 Slope (%) Spacing (feet)

 5 - 15 300 

 >15 - 30 200 

 >30 100 

c. Construct slope breakers to divert surface flow to a stable area without 

causing water to pool or erode behind the breaker. In the absence of a 

stable area, construct appropriate energy-dissipating devices at the end 

of the breaker. 

d. Slope breakers may extend slightly (about 4 feet) beyond the edge of 

the construction right-of-way to effectively drain water off the 

disturbed area. Where slope breakers extend beyond the edge of the 

construction right-of-way, they are subject to compliance with all 

applicable survey requirements. 

C. SOIL COMPACTION MITIGATION 

1. Test topsoil and subsoil for compaction at regular intervals in agricultural and 

residential areas disturbed by construction activities. Conduct tests on the 

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Bayou Casotte Plan 13 September 2005 

same soil type under similar moisture conditions in undisturbed areas to 

approximate preconstruction conditions. Use penetrometers or other 

appropriate devices to conduct tests. 

2. Plow severely compacted agricultural areas with a paraplow or other deep 

tillage implement. In areas where topsoil has been segregated, plow the 

subsoil before replacing the segregated topsoil. 

Alternatively, make arrangements with the landowner to plant and plow 

under a "green manure" crop, such as alfalfa, to decrease soil bulk density 

and improve soil structure. If subsequent construction and cleanup activities 

result in further compaction, conduct additional tilling. 

3. Perform appropriate soil compaction mitigation in severely compacted 

residential areas. 

D. REVEGETATION 

1. General 

a. The project sponsor is responsible for ensuring successful 

revegetation of soils disturbed by project-related activities, except as 

noted in section V.D.1.b. 

b. Restore all turf, ornamental shrubs, and specialized landscaping in 

accordance with the landowner's request, or compensate the 

landowner. Restoration work must be performed by personnel 

familiar with local horticultural and turf establishment practices. 

2. Soil Additives (for those Project areas utilized via an easement 

agreement only) 

Fertilize and add soil pH modifiers in accordance with written 

recommendations obtained from the local soil conservation authority, land 

management agencies, or landowner. Incorporate recommended soil pH 

modifier and fertilizer into the top 2 inches of soil as soon as possible after 

application. 

3. Seeding Requirements (for those Project areas utilized via an 

easement agreement only)

a. Prepare a seedbed in disturbed areas to a depth of 3 to 4 inches using 

appropriate equipment to provide a firm seedbed. When 

hydroseeding, scarify the seedbed to facilitate lodging and 

germination of seed. 

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Bayou Casotte Plan 14 September 2005 

b. Seed disturbed areas in accordance with written recommendations for 

seed mixes, rates, and dates obtained from the local soil conservation 

authority or as requested by the landowner or land management 

agency. Seeding is not required in actively cultivated croplands 

unless requested by the landowner. 

c. Perform seeding of permanent vegetation within the recommended 

seeding dates. If seeding cannot be done within those dates, use 

appropriate temporary erosion control measures discussed in section 

IV.F. and perform seeding of permanent vegetation at the beginning 

of the next recommended seeding season. Lawns may be seeded on a 

schedule established with the landowner. 

d. In the absence of written recommendations from the local soil 

conservation authorities, seed all disturbed soils within 6 working 

days of final grading, weather and soil conditions permitting, subject 

to the specifications in section V.D.3.a-c. 

e. Base seeding rates on Pure Live Seed. Use seed within 12 months of 

seed testing. 

f. Treat legume seed with an inoculant specific to the species using the 

manufacturer’s recommended rate of inoculant appropriate for the 

seeding method (broadcast, drill, or hydro). 

g. In the absence of written recommendations from the local soil 

conservation authorities, landowner, or land managing agency to the 

contrary, a seed drill equipped with a cultipacker is preferred for seed 

application. 

 

Broadcast or hydroseeding can be used in lieu of drilling at double the 

recommended seeding rates. Where seed is broadcast, firm the seedbed 

with a cultipacker or imprinter after seeding. In rocky soils or where site 

conditions may limit the effectiveness of this equipment, other 

alternatives may be appropriate (e.g., use of a chain drag) to lightly cover 

seed after application, as approved by the Environmental Inspector. 

VI. OFF-ROAD VEHICLE CONTROL 

To each owner or manager of forested lands offer to install and maintain measures to control 

unauthorized vehicle access to the right-of-way. These measures may include: 

A. Signs; 

B. Fences with locking gates; 

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Bayou Casotte Plan 15 September 2005 

C. Slash and timber barriers, pipe barriers, or a line of boulders across the right-of-way; 

and 

D. Conifers or other appropriate trees or shrubs across the right-of-way. 

VII. POST-CONSTRUCTION ACTIVITIES 

A. MONITORING AND MAINTENANCE 

1. Conduct follow-up inspections of all disturbed areas after the first and 

second growing seasons to determine the success of revegetation. If, after 

the first growing season following construction, revegetation is deemed 

successful, no additional monitoring will take place during the next 

growing season. 

2. Revegetation in non-agricultural areas shall be considered successful if upon 

visual survey the density and cover of non-nuisance vegetation are similar in 

density and cover to adjacent undisturbed lands. In agricultural areas, 

revegetation shall be considered successful if crop yields are similar to 

adjacent undisturbed portions of the same field. 

 Continue revegetation efforts until revegetation is successful. If, after the 

first growing season following construction, revegetation is deemed 

successful, no additional monitoring will take place during the next 

growing season. 

3. Monitor and correct problems with drainage and irrigation systems resulting 

from pipeline construction in active agricultural areas until restoration is 

successful. 

4. Restoration shall be considered successful if the right-of-way surface 

condition is similar to adjacent undisturbed lands, construction debris is 

removed (unless requested otherwise by the land owner or land managing 

agency), revegetation is successful, and proper drainage has been restored. 

5. Along the Natural Gas System Interconnections only, routine vegetation 

maintenance clearing shall not be done more frequently than every 3 years. 

However, to facilitate periodic corrosion and leak surveys, a corridor not 

exceeding 10 feet in width centered on the pipeline may be maintained 

annually in an herbaceous state. In no case shall routine vegetation 

maintenance clearing occur between April 15 and August 1 of any year. 

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Bayou Casotte Plan 16 September 2005 

6. Efforts to control unauthorized off-road vehicle use, in cooperation with the 

landowner, shall continue throughout the life of the project. Maintain signs, 

gates, and vehicle trails as necessary. 

B. REPORTING 

1. The project sponsor shall maintain records that identify by milepost: 

a. method of application, application rate, and type of fertilizer, pH 

modifying agent, seed, and mulch used; 

b. acreage treated; 

c. dates of backfilling and seeding; 

d. names of landowners requesting special seeding treatment and a 

description of the follow-up actions; and 

e. any problem areas and how they were addressed. 

2. The project sponsor shall file with the Secretary quarterly activity reports 

documenting problems, including those identified by the landowner, and 

corrective actions taken for at least 2 years following construction only in the 

event that one or more problems have been identified. 

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Bayou Casotte Plan 17 September 2005 

VARIANCE DETAILED DISCUSSION 

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Bayou Casotte Plan 18 September 2005 

1. Section II.A.1. 

 Add – “...(a “spread” is defined herein as both the Terminal and the Natural Gas 

System Interconnections)...”

Due to the point-source and slower-paced nature of LNG terminal construction and the short 

length of the Natural Gas System Interconnections, Bayou Casotte Energy anticipates that one 

(1) Environmental Inspector shall suffice for the Project. 

2 Section III.F.1. and 2. 

 Add – “...for those Project areas utilized via an easement agreement only...” 

Being that the proposed Terminal facilities will be located on fee property owned by CUSA, it 

shall be restored in accordance with the standard practices relative to LNG terminal construction. 

Bayou Casotte Energy feels that coordination with the appropriate agencies regarding seed 

mixtures, control of noxious weeds, etc. is not necessary. 

3. Section IV.A.2. 

 Add – “Bayou Casotte Energy is proposing a nominal construction right-of-way of 110 

feet in several locations along the pipeline route. The soils expected along the pipeline route 

are predominately poorly drained mucky sandy clay loam that is frequently flooded. 

Moreover, the water table is typically very close to the surface. These conditions will adversely 

affect the slope and stability of the excavation and indicate greater than normal excavation 

(ditch) widths and spoil volume. In addition to these complications, an expanded construction 

right-of-way is needed due to the containment of a dual pipeline configuration.” 

Adequate workspace is the single greatest factor controlling the efficiency of pipeline 

construction with respect to time, environmental impact, and cost. Bayou Casotte Energy 

expended considerable effort in the development of what it considers the optimum construction

right-of-way width for the Natural Gas System Interconnections. This width was determined 

based on the recommendations outlined in the FERC Plan and Procedures, the collective 

experience of pipeline construction in southern Mississippi, and the conditions expected on this 

Project. 

The construction right-of-way width requested is based on the experience of the Bayou Casotte 

Energy team, field inspections and the knowledge of the subsoil profile. 

SSURGO database information and other publicly available sources were used by Bayou Casotte 

Energy to confirm the probable soils that will be encountered along the proposed pipeline route. 

These sources contain valuable information regarding soils and their general properties, and 

support Bayou Casotte Energy’s position that the excavations will be difficult. 

The proposed pipeline corridor associated with the Natural Gas Systems Interconnections 

traverses essentially flat coastal plain terrains. The subsoil profile expected involves 

predominantly non-cohesive material with a relatively high water table. The soils are 

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Bayou Casotte Plan 19 September 2005 

predominately poorly drained mucky sandy clay loam that is frequently flooded that typically 

exhibit loose density. Under these soil conditions, unstable excavations and dewatering 

problems would be encountered by any construction, which involves earth moving. Unstable 

soils for the purposes of this discussion refer to soils that present instabilities during construction 

and not to long-term instabilities that would affect the integrity of the installed pipeline. 

The length of time an excavation is open is of critical importance in these types of soils. 

Wetting-drying cycles will cause changes in the strength of granular soils; the longer an 

excavation is left open the more likely it may become unstable. Granular soils are also 

susceptible to shock and vibration resulting from working equipment, pile driving, etc. This is 

another factor why the right-of-way width as requested by Bayou Casotte Energy is necessary. 

Decreased construction right-of-way width will slow down the progress resulting in increased 

excavation time. This will lead to the increased potential for sloughing in the ditch. 

Unless some kind of support is provided, the soils encountered will lead to wide trench and borepit excavations, and extensive dewatering.

In general, due to the fine grained nature of the mucky sandy clay loam, low permeabilities are 

expected. As a result, drainage may not be immediate and unstable rapid draw-down conditions 

may occur if there are rapid differences in water elevations between the trench and the 

surrounding natural terrain. Also, local liquefaction may occur as a result of vibrations, spoil 

damping, or other sudden loading. 

Slope stability analysis indicates failures may occur that would involve the adjacent spoil, unless 

the edge of the mound is kept at a minimum distance on the order of seven feet from the edge of 

the trench. It must be kept in mind that any slide involves an extra volume to be removed to 

clear the trench; such extra volume would require additional workspace and might trigger new 

slides if simply dumped on top of the existing spoil. 

All of the conditions listed will adversely affect the slope and stability of the excavation and 

indicate greater than normal excavation (ditch) widths and spoil volumes. 

4. Section IV.B.1. 

Add – “...or as requested by a landowner for those Project areas utilized via an 

easement agreement only:” 

The nature of LNG terminal construction dictates a tremendous amount of earthwork (including 

dredge and fill) to prepare the area for the installation of the facilities, particularly, the tanks. 

Additionally, the proposed Terminal facilities will be located on fee property owned by CUSA. 

Bayou Casotte Energy feels that topsoil and subsoil segregation is not required within this area 

of the Project. 

5. Section IV.F.1.c 

Modify – “Direct the outfall of each temporary slope breaker to a stable, well vegetated 

area or construct an energy-dissipating device at the end of the slope breaker and off the 

construction right-of-way. Extend each temporary slope breaker marginally off the disturbed 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
PLAN

Bayou Casotte Plan 20 September 2005 

right-of-way so that the outfall exits onto a stable, well vegetated area. If a stable, well 

vegetated area does not exist, construct an energy dissipater at the end of the slope breaker. 

These structures will not adversely affect sensitive environmental areas.” 

In order to provide the environmental protection specified in the FERC Plan, Bayou Casotte 

Energy will need to marginally extend the temporary slope breaker off the certificated 

construction right-of-way with landowner permission. For a temporary slope breaker to function 

properly, it must extend slightly beyond the limits of the disturbance and therefore beyond the 

certificated right-of-way but within the previously surveyed and environmentally cleared areas. 

To minimize the migration of eroded sediments, the diverted water will be filtered through 

existing vegetation or an energy dissipater at the end of the breaker. 

6. Section IV.F.2.d 

Add – “Small openings will be left in the sediment barriers to allow temporary and 

permanent slope breakers to exit the certificated right-of-way.” 

In areas where a side slope and a downhill slope exist, openings must be made in the sediment 

barrier to allow slope breakers to exit the right-of-way. If the openings are not constructed, the 

breaker will direct water towards the sediment barrier, which will act to channel the water 

downhill. This channeling can cause massive erosion that may undermine the function of the 

sediment barrier by allowing sediment to flow uncontrolled off the right-of-way. 

7. Section IV.F.3.c. 

 Add – “...in those Project areas utilized via an easement agreement only...” 

Being that the nature of LNG terminal construction is of long duration and the proposed 

Terminal facilities will be located on fee property owned by CUSA, it shall be temporarily 

restored in accordance with the standard practices relative to LNG terminal construction. Bayou 

Casotte Energy feels that the timeframes and measures outlined in the Plan should not apply 

allowing flexibility in the field. However, Bayou Casotte Energy will constantly monitor the 

need for such measures and apply them accordingly should the need arise. 

8. Section V.A.1. and 5. 

 Add – “...in those Project areas utilized via an easement agreement only.” 

Being that the nature of LNG terminal construction is of long duration and the proposed 

Terminal facilities will be located on fee property owned by CUSA, it shall be permanently 

restored in accordance with the standard practices relative to LNG terminal construction. Bayou 

Casotte Energy feels that these timeframes and measures outlined in the Plan should not apply 

allowing flexibility in the field. However, Bayou Casotte Energy will constantly monitor the 

need for such measures and apply them accordingly should the need arise. 

9. Section V.B.1.c and d. 

Add – “...or as directed by an engineer or similarly qualified professional.” 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
PLAN

Bayou Casotte Plan 21 September 2005 

Bayou Casotte Energy proposes to abide by the current Plan requirement, or alternatively, install 

the trench breakers as directed by an engineer or similar qualified professional as long as the 

same or greater amount of protection is obtained as if using the spacing for permanent slope 

breakers. The utilization of an engineer or similar qualified professional will enable the 

placement of the trench breakers to be at optimum spacing warranted for the site-specific 

conditions.

10. Section V.D.2. and 3. 

 Add – “...(for those Project areas utilized via an easement agreement only)” 

Being that the proposed Terminal facilities will be located on fee property owned by CUSA, it 

shall be restored in accordance with the standard practices relative to LNG terminal construction. 

Bayou Casotte Energy wishes to maintain flexibility within the Terminal area as it relates to 

these measures while achieving the same goal of a stabilized restoration. 

11. Section VII.A.1. and 2. 

Modify and add – “Conduct follow-up inspections of all disturbed areas after the first 

and second growing seasons to determine the success of revegetation. If, after the first growing 

season following construction, revegetation is deemed successful, no additional monitoring 

will take place during the next growing season.” 

If revegetation of the disturbed areas is established after the first growing season, Bayou Casotte 

Energy will not plan on conducting follow up inspections on the Project areas. If there are areas 

where revegetation is not considered successful after the first growing season, Bayou Casotte 

Energy will conduct another inspection of the affected areas after the second growing season.

12. Section VII.A.5. 

 Add – “Along the Natural Gas System Interconnections only,... 

Due to the nature of LNG terminal grounds maintenance, this section shall only apply to the 

Natural Gas System Interconnections. 

13. Section VII.B.2. 

Add – “...only in the event that one or more problems have been identified.” 

If there are no problems or complaints filed, Bayou Casotte Energy proposes to discontinue the 

quarterly reports and issue them on an as needed basis. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
PLAN

Bayou Casotte Plan 22 September 2005 

Figures 

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Bayou Casotte Plan 23 

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PLAN 

FIGURES 

Bayou Casotte Plan 24 September 2005 

 

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PLAN 

FIGURES 

Bayou Casotte Plan 25 September 2005 

 

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PLAN 

FIGURES 

Bayou Casotte Plan 26 September 2005 

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PLAN 

FIGURES 

Bayou Casotte Plan 27 September 2005 

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PLAN 

FIGURES 

Bayou Casotte Plan 28 September 2005 

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PLAN 

FIGURES 

Bayou Casotte Plan 29 September 2005 

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PLAN 

FIGURES 

Bayou Casotte Plan 30 September 2005 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX B2 

BAYOU CASOTTE ENERGY’S PROCEDURES

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
BAYOU CASOTTE ENERGY’S 

WETLAND AND WATERBODY CONSTRUCTION AND 

MITIGATION PROCEDURES 

JULY 2005 

INTRODUCTION

Bayou Casotte Energy LLC (Bayou Casotte Energy) has developed the following 

guidelines to be used during the construction of the Casotte Landing LNG Terminal 

Project (Project) proposed near Pascagoula in Jackson County, Mississippi. 

This document has been created in conjunction and is consistent with the Federal 

Energy Regulatory Commission (FERC) Office of Energy Projects (OEP) construction, 

restoration and maintenance guidelines commonly referred to as the Wetland and 

Waterbody Construction and Mitigation Procedures (Procedures), 1/17/2003 Version. 

Bayou Casotte Energy has reviewed the FERC Procedures and has determined that 

adoption of the Procedures to address erosion and sedimentation control and 

environmental construction issues that may be encountered on the Project. 

Bayou Casotte Energy is committed to assuring the necessary efforts are undertaken for 

each new proposed project to review and verify that all requirements and/or guidelines 

are applicable and can be complied with during construction and operational 

maintenance of a project. 

In the event Bayou Casotte Energy is unable to comply and/or accept the guidelines set 

out in the FERC Procedures, variances will be requested from the specific guideline or 

requirement with full justification for the requested variance offering equal or better 

protection for the protected resource. 

This document is a preliminary document, which will be further modified based on sitespecific conditions or requests made and agreed to by Casotte Landing and respective 

landowners, permitting agencies and/or other regulatory agencies with jurisdictional 

authority over resources that may be impacted by the construction of this Project. 

Figures will be added to this document for clarification and utilization during the 

construction phase of the proposed Project. 

Bayou Casotte Energy has identified and is requesting several variances to the FERC 

Procedures, which are outlined in the following.

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
LIST OF FIGURES 

TOC 

LIST OF FIGURES 

 No. Description 

Proc-1 Typical Timber Mat Bridge (w/ Culvert) Equipment Crossing 

Proc-2 Typical Timber Mat Bridge (w/o Culvert) Equipment Crossing 

Proc-3 Typical Rock and Flume Equipment Crossing 

Proc-4 Typical Portable Bridge Equipment Crossing 

Proc-5 Dry Waterbody Crossing (Method 2B - Pump-Around) 

Proc-6 Dry Waterbody Crossing (Method 2A - Flumed) 

Proc-7 Typical Workspace Layout Directional Drill Method 

Proc-8 Wet Waterbody Crossing (Method 1 - Open-Cut) 

Proc-9 Standard/Conventional Wetland Construction (Method I or II) 

Proc-10 Wet Waterbody Crossing (Method III - Push/Pull) 

Proc-11 Typical Energy Dissipater 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
PROCEDURES 

TOC 

BAYOU CASOTTE ENERGY’S WETLAND AND WATERBODY 

CONSTRUCTION AND MITIGATION PROCEDURES 

TABLE OF CONTENTS 

I. APPLICABILITY................................................................................................................1 

II. PRECONSTRUCTION FILING .........................................................................................2 

III. ENVIRONMENTAL INSPECTORS..................................................................................3 

IV. PRECONSTRUCTION PLANNING..................................................................................3 

V. WATERBODY CROSSINGS.............................................................................................5 

A. NOTIFICATION PROCEDURES AND PERMITS........................................................5 

B. INSTALLATION.............................................................................................................5 

1. Time Window for Construction...............................................................................5 

2. Extra Work Areas ....................................................................................................6 

3. General Crossing Procedures...................................................................................6 

4. Spoil Pile Placement and Control ............................................................................7 

5. Equipment Bridges...................................................................................................7 

6. Dry-Ditch Crossing Methods...................................................................................8 

7. Crossings of Minor Waterbodies ...........................................................................10 

8. Crossings of Intermediate Waterbodies.................................................................10 

9. Crossings of Major Waterbodies ...........................................................................10 

10. Temporary Erosion and Sediment Control ............................................................11 

11. Trench Dewatering.................................................................................................12 

C. RESTORATION............................................................................................................12 

D. POST-CONSTRUCTION MAINTENANCE.................................................................13 

VI. WETLAND CROSSINGS.................................................................................................13 

A. GENERAL....................................................................................................................13 

B. INSTALLATION...........................................................................................................15 

1. Extra Work Areas and Access Roads ....................................................................15 

2. Crossing Procedures...............................................................................................16 

3. Temporary Sediment Control ................................................................................18 

4. Trench Dewatering.................................................................................................18 

C. RESTORATION............................................................................................................19 

D. POST-CONSTRUCTION MAINTENANCE.................................................................19 

VII. HYDROSTATIC TESTING..............................................................................................20 

A. NOTIFICATION PROCEDURES AND PERMITS......................................................20 

B. GENERAL....................................................................................................................20 

C. INTAKE SOURCE AND RATE....................................................................................21 

D. DISCHARGE LOCATION, METHOD, AND RATE....................................................21 

VARIANCES DETAILED DISCUSSION ...................................................................................22 

FIGURES.......................................................................................................................................28 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Page 1

BAYOU CASOTTE ENERGY’S 

WETLAND AND WATERBODY CONSTRUCTION AND 

MITIGATION PROCEDURES 

WETLAND AND WATERBODY CONSTRUCTION AND MITIGATION 

PROCEDURES (PROCEDURES) 

Construction activities associated with Casotte Landing are both similar to, and different from, 

typical construction activities related to natural gas facilities, particularly as they apply to 

wetland resource areas and waterbodies. The similarities are in that there are wetland resource 

areas and waterbodies requiring total avoidance and other areas that are being used for temporary 

workspace. There are also differences in that certain wetland resource areas will be permanently 

filled and waterbodies permanently rerouted/relocated per the approved Terminal site design. 

Ultimate care must be used when distinguishing between these wetland resource areas and 

waterbodies on the approved Project plans as different construction techniques and mitigation 

measures will be applied dependent upon the area in question. Only those wetland resource 

areas and waterbodies to be avoided or used as temporary workspace will be marked in the field. 

Workspace buffers associated with these wetland resource areas and waterbodies will be applied 

according to the approved site-specific plans. 

I. APPLICABILITY 

A. The intent of these Procedures is to assist applicants by identifying baseline 

mitigation measures for minimizing the extent and duration of project-related 

disturbance on wetlands and waterbodies. The project sponsors should specify in 

their applications for a FERC Certificate (Certificate) any individual measures in 

these Procedures they consider unnecessary, technically infeasible, or unsuitable 

due to local conditions and to fully describe any alternative measures they would 

use. Applicants should also explain how those alternative measures would 

achieve a comparable level of mitigation. 

Bayou Casotte Energy has prepared variances to portions of these Procedures 

and noted them in the text. Detailed discussions associated with these variances 

are attached to the end of this plan.

 

 Once a project is certificated, further changes can be approved. Any such 

changes from the measures in these Procedures (or the applicant’s approved 

procedures) will be approved by the Director of the Office of Energy Projects 

(Director), upon the applicant’s written request, if the Director agrees that an 

alternative measure: 

1. provides equal or better environmental protection; 

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2. is necessary because a portion of these Procedures is infeasible or 

unworkable based on project-specific conditions; or 

3. is specifically required in writing by another Federal, state, or Native 

American land management agency for the portion of the project on its 

land or under its jurisdiction. 

Any requirements in these Procedures to file material with the Secretary of the 

FERC (Secretary) do not apply to projects undertaken under the provisions of the 

blanket certificate program. This exemption does not apply to a request for 

alternative measures. 

Project-related impacts on non-wetland areas are addressed in the staff’s Upland 

Erosion Control, Revegetation, and Maintenance Plan (Plan). 

B. DEFINITIONS 

1. "Waterbody" includes 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: 

a. "minor waterbody" includes all waterbodies less than or equal to 

10 feet wide at the water's edge at the time of crossing; 

b. "intermediate waterbody" includes all waterbodies greater than 10 

feet wide but less than or equal to 100 feet wide at the water's edge 

at the time of crossing; and 

c. "major waterbody" includes all waterbodies greater than 100 feet 

wide at the water's edge at the time of crossing. 

2. "Wetland" includes any area that is not in actively cultivated or rotated 

cropland and that satisfies the requirements of the current Federal 

methodology for identifying and delineating wetlands. 

 

II. PRECONSTRUCTION FILING 

1. The following information shall be filed with the Secretary prior to the beginning 

of construction: 

1. the hydrostatic testing information specified in section VII.B.3. and a 

wetland delineation report as described in section VI.A.1., if applicable; 

and 

2. a schedule identifying when trenching or blasting would occur within each 

waterbody greater than 10 feet wide, or within any designated coldwater 

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fishery. The project sponsor shall revise the schedule as necessary to 

provide FERC staff at least 14 days advance notice. Changes within this 

last 14-day period must provide for at least 48 hours advance notice. 

2. The following site-specific construction plans required by these Procedures must 

be filed with the Secretary for the review and written approval by the Director: 

1. plans for extra work areas that would be closer than 50 feet from a 

waterbody or wetland; 

2. plans for major waterbody crossings; 

3. plans for the use of a construction right-of-way greater than 75 feet wide 

in wetlands; and 

4. plans for horizontal directional drill (HDD) "crossings" of wetlands or 

waterbodies. 

III. ENVIRONMENTAL INSPECTORS 

A. At least one Environmental Inspector having knowledge of the wetland and 

waterbody conditions in the project area is required for each construction spread 

(a “spread” is defined herein as both the Terminal and the Natural Gas System 

Interconnections). The number and experience of Environmental Inspectors 

assigned to each construction spread should be appropriate for the length of the 

construction spread and the number/significance of resources affected. 

B. The Environmental Inspector's responsibilities are outlined in the Upland Erosion 

Control, Revegetation, and Maintenance Plan (Plan). 

IV. PRECONSTRUCTION PLANNING 

A. A copy of the Stormwater Pollution Prevention Plan (SWPPP) prepared for 

compliance with the U.S. Environmental Protection Agency's (EPA) National 

Stormwater Program General Permit requirements must be available in the field 

on each construction spread. The SWPPP shall contain Spill Prevention and 

Response Procedures that meet the requirements of state and Federal agencies. 

1. It shall be the responsibility of the project sponsor and its contractors to 

structure their operations in a manner that reduces the risk of spills or the 

accidental exposure of fuels or hazardous materials to waterbodies or 

wetlands. The project sponsor and its contractors must, at a minimum, 

ensure that: 

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a. all employees handling fuels and other hazardous materials are 

properly trained; 

b. all equipment is in good operating order and inspected on a regular 

basis; 

c. fuel trucks transporting fuel to on-site equipment travel only on 

approved access roads; 

d. for those Project areas utilized via an easement agreement only,

all equipment is parked overnight and/or fueled at least 100 feet 

from a waterbody or in an upland area at least 100 feet from a 

wetland boundary. These activities can occur closer only if the 

Environmental Inspector finds, in advance, no reasonable 

alternative and the project sponsor and its contractors have taken 

appropriate steps (including secondary containment structures) to 

prevent spills and provide for prompt cleanup in the event of a 

spill. 

e. for those Project areas utilized via an easement agreement only,

hazardous materials, including chemicals, fuels, and lubricating 

oils, are not stored within 100 feet of a wetland, waterbody, or 

designated municipal watershed area, unless the location is 

designated for such use by an appropriate governmental authority. 

This applies to storage of these materials and does not apply to 

normal operation or use of equipment in these areas; and 

f. for those Project areas utilized via an easement agreement only,

concrete coating activities are not performed within 100 feet of a 

wetland or waterbody boundary, unless the location is an existing 

industrial site designated for such use. 

2. The project sponsor and its contractors must structure their operations in a 

manner that provides for the prompt and effective cleanup of spills of fuel 

and other hazardous materials. At a minimum, the project sponsor and its 

contractors must: 

a. ensure that each construction crew (including cleanup crews) has 

on hand sufficient supplies of absorbent and barrier materials to 

allow the rapid containment and recovery of spilled materials and 

knows the procedure for reporting spills; 

b. ensure that each construction crew has on hand sufficient tools and 

material to stop leaks; 

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c. know the contact names and telephone numbers for all local, state, 

and Federal agencies (including, if necessary, the U. S. Coast 

Guard and the National Response Center) that must be notified of a 

spill; and 

d. follow the requirements of those agencies in cleaning up the spill, 

in excavating and disposing of soils or other materials 

contaminated by a spill, and in collecting and disposing of waste 

generated during spill cleanup. 

B. AGENCY COORDINATION 

The project sponsor must coordinate with the appropriate local, state, and Federal 

agencies as outlined in these Procedures and in the Certificate. 

 

V. WATERBODY CROSSINGS 

A. NOTIFICATION PROCEDURES AND PERMITS 

1. Apply to the U.S. Army Corps of Engineers (COE), or its delegated 

agency, for the appropriate wetland and waterbody crossing permits. 

2. Provide written notification to authorities responsible for potable surface 

water supply intakes located within 3 miles downstream of the crossing at 

least 1 week before beginning work in the waterbody, or as otherwise 

specified by that authority. 

3. Apply for state-issued waterbody crossing permits and obtain individual or 

generic section 401 water quality certification or waiver. 

4. Notify appropriate state authorities at least 48 hours before beginning 

trenching or blasting within the waterbody, or as specified in state permits. 

B. INSTALLATION 

1. Time Window for Construction 

Unless expressly permitted or further restricted by the appropriate state 

agency in writing on a site-specific basis, instream work, except that 

required to install or remove equipment bridges, must occur during the 

following time windows: 

a. coldwater fisheries - June 1 through September 30; and 

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b. coolwater and warmwater fisheries - June 1 through November 

2. Extra Work Areas 

a. For those Project areas utilized via an easement agreement only,

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. 

b. For those Project areas utilized via an easement agreement only,

the project sponsor shall file with the Secretary for review and 

written approval by the Director, a site-specific construction plan 

for each extra work area with a less than 50-foot setback from the 

water's edge, (except where the adjacent upland consists of 

actively cultivated or rotated cropland or other disturbed land) and 

a site-specific explanation of the conditions that will not permit a 

50-foot setback. 

c. Limit clearing of vegetation between extra work areas and the edge 

of the waterbody to the certificated construction right-of-way. 

d. Limit the size of extra work areas to the minimum needed to 

construct the waterbody crossing. 

3. General Crossing Procedures 

a. Comply with the COE, or its delegated agency, permit terms and 

conditions. 

b. Construct crossings as close to perpendicular to the axis of the 

waterbody channel as engineering and routing conditions permit. 

c. If the pipeline parallels a waterbody, attempt to maintain at least 15 

feet of undisturbed vegetation between the waterbody (and any 

adjacent wetland) and the construction right-of-way. 

d. Where waterbodies meander or have multiple channels, route the 

pipeline to minimize the number of waterbody crossings. 

e. Maintain adequate flow rates to protect aquatic life, and prevent 

the interruption of existing downstream uses. 

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f. For those Project areas utilized via an easement agreement only,

Waterbody buffers (extra work area setbacks, refueling 

restrictions, etc.) must be clearly marked in the field with signs 

and/or highly visible flagging until construction-related ground 

disturbing activities are complete. 

4. Spoil Pile Placement and Control 

a. For those Project areas utilized via an easement agreement only,

all spoil from minor and intermediate waterbody crossings, and 

upland spoil from major waterbody crossings, must be placed in 

the construction right-of-way at least 10 feet from the water's edge 

or in additional extra work areas as described in section V.B.2. 

b. Use sediment barriers to prevent the flow of spoil or heavily siltladen water into any waterbody. 

5. Equipment Bridges 

a. Only clearing equipment and equipment necessary for installation 

of equipment bridges may cross waterbodies prior to bridge 

installation. Limit the number of such crossings of each waterbody 

to one per piece of clearing equipment. 

b. Construct equipment bridges to maintain unrestricted flow and to 

prevent soil from entering the waterbody. Examples of such 

bridges include: 

(1) equipment pads and culvert(s) where culverts are 

necessary to support the equipment pads; 

(2) equipment pads or railroad car bridges without culverts; 

(3) clean rock fill, and culvert(s); and 

(4) flexi-float or portable bridges or salvaged flat bed rail cars 

or equivalent. 

Additional options for equipment bridges may be utilized that 

achieve the performance objectives noted above. Do not use soil 

to construct or stabilize equipment bridges. 

c. Design and maintain each equipment bridge to accommodate the 

highest flow expected to occur while the bridge is in place as 

determined by historical records for the expected construction 

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period or by an engineer in consultation with applicable state 

agencies and the USACE. Align culverts to prevent bank erosion 

or streambed scour. If necessary, install energy dissipating devices 

downstream of the culverts. 

d. Design and maintain equipment bridges to prevent soil from 

entering the waterbody. 

e. Remove equipment bridges as soon as possible after permanent 

seeding unless the COE, or its delegated agency, authorizes it as a 

permanent bridge. 

f. If there will be more than 1 month between final cleanup and the 

beginning of permanent seeding and reasonable alternative access 

to the right-of-way is available, remove equipment bridges as soon 

as possible after final cleanup. 

6. Dry-Ditch Crossing Methods 

a. Unless approved otherwise by the appropriate state agency, 

install the pipeline using one of the dry-ditch methods outlined 

below for crossings of waterbodies up to 30 feet wide (at the 

water's edge at the time of construction) that are state-designated 

as either coldwater or significant coolwater or warmwater 

fisheries. 

b. Dam and Pump 

(1) The dam-and-pump method may be used without prior 

approval for crossings of waterbodies where pumps can 

adequately transfer streamflow volumes around the work 

area, and there are no concerns about sensitive species 

passage. 

(2) Implementation of the dam-and-pump crossing method 

must meet the following performance criteria: 

(i) use sufficient pumps, including on-site backup 

pumps, to maintain downstream flows; 

(ii) construct dams with materials that prevent sediment 

and other pollutants from entering the waterbody 

(e.g., sandbags or clean gravel with plastic liner); 

(iii) screen pump intakes; 

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(iv) prevent streambed scour at pump discharge; and 

(v) monitor the dam and pumps to ensure proper 

operation throughout the waterbody crossing. 

 

c. Flume Crossing 

The flume crossing method requires implementation of the 

following steps: 

(1) install flume pipe after blasting (if necessary), but before 

any trenching; 

(2) use sand bag or sand bag and plastic sheeting diversion 

structure or equivalent to develop an effective seal and to 

divert stream flow through the flume pipe (some 

modifications to the stream bottom may be required in to 

achieve an effective seal); 

(3) properly align flume pipe(s) to prevent bank erosion and 

streambed scour; 

(4) do not remove flume pipe during trenching, pipelaying, or 

backfilling activities, or initial streambed restoration 

efforts; and 

(5) remove all flume pipes and dams that are not also part of 

the equipment bridge as soon as final cleanup of the stream 

bed and bank is complete; 

d. Horizontal Directional Drill (HDD) 

To the extent they were not provided as part of the pre-certification 

process, for each waterbody or wetland that would be crossed 

using the HDD method, provide a plan that includes: 

(1) site-specific construction diagrams that show the location 

of mud pits, pipe assembly areas, and all areas to be 

disturbed or cleared for construction; 

(2) a description of how an inadvertent release of drilling mud 

would be contained and cleaned up; and 

(3) a contingency plan for crossing the waterbody or wetland 

in the event the directional drill is unsuccessful and how the 

abandoned drill hole would be sealed, if necessary. 

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 7. Crossings of Minor Waterbodies 

Where a dry-ditch crossing is not required, minor waterbodies may be 

crossed using the open-cut crossing method, with the following 

restrictions: 

 a. except for blasting and other rock breaking measures, complete 

instream construction activities (including trenching, pipe 

installation, backfill, and restoration of the streambed contours) 

within 24 hours. Streambanks and unconsolidated streambeds may 

require additional restoration after this period; 

 b. limit use of equipment operating in the waterbody to that needed to 

construct the crossing; and 

 c. equipment bridges are not required at minor waterbodies that do 

not have a state-designated fishery classification (e.g., agricultural 

or intermittent drainage ditches). However, if an equipment bridge 

is used it must be constructed as described in section V.B.5. 

8. Crossings of Intermediate Waterbodies 

Where a dry-ditch crossing is not required, intermediate waterbodies may 

be crossed using the open-cut crossing method, with the following 

restrictions: 

a. complete instream construction activities (not including blasting 

and other rock breaking measures) within 48 hours, unless sitespecific conditions (i.e., local noise ordinances, etc.) make 

completion within 48 hours infeasible; 

b. limit use of equipment operating in the waterbody to that needed to 

construct the crossing; and 

c. all other construction equipment must cross on an equipment 

bridge as specified in section V.B.5. 

9. Crossings of Major Waterbodies 

Before construction, the project sponsor shall file with the Secretary for 

the review and written approval by the Director a detailed, site-specific 

construction plan and scaled drawings identifying all areas to be disturbed 

by construction for each major waterbody crossing (the scaled drawings 

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are not required for any offshore portions of pipeline projects). This plan 

should be developed in consultation with the appropriate state and Federal 

agencies and should include extra work areas, spoil storage areas, 

sediment control structures, etc., as well as mitigation for navigational 

issues. 

The Environmental Inspector may adjust the final placement of the erosion 

and sediment control structures in the field to maximize effectiveness. 

10. Temporary Erosion and Sediment Control 

Install sediment barriers (as defined in section IV.F.2.a. of the Plan) of the 

waterbody or adjacent upland. Sediment barriers must be properly 

maintained throughout construction and reinstalled as necessary (such as 

after backfilling of the trench) until replaced by permanent erosion 

controls or restoration of adjacent upland areas is complete. Temporary 

erosion and sediment control measures are addressed in more detail in the 

Plan; however, the following specific measures must be implemented at 

stream crossings: 

a. install sediment barriers across the entire construction right-of-way 

at all waterbody crossings with provisions to access any 

equipment bridges present, where necessary to prevent the flow of 

sediments into the waterbody. In the travel lane, these may consist 

of removable sediment barriers or drivable berms. Removable 

sediment barriers can be removed during the construction day, but 

must be re-installed after construction has stopped for the day 

and/or when heavy precipitation is imminent; 

b. where waterbodies are adjacent to the construction right-of-way, 

install sediment barriers along the edge of the construction rightof-way as necessary to contain spoil and sediment within the 

construction right-of-way; and 

c. use trench plugs at all waterbody crossings, as necessary, to 

prevent diversion of water into upland portions of the pipeline 

trench and to keep any accumulated trench water out of the 

waterbody. 

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11. Trench Dewatering 

Dewater the trench (either on or off the construction right-of-way) in a 

manner that does not cause erosion and does not result in heavily silt-laden 

water flowing into any waterbody. Remove the dewatering structures as 

soon as possible after the completion of dewatering activities. 

C. RESTORATION 

1. Use clean gravel or native cobbles for the upper 1 foot of trench backfill in 

all waterbodies that contain coldwater fisheries. 

2. For open-cut crossings, stabilize waterbody banks and install temporary 

sediment barriers within 24 hours of completing instream construction 

activities. For dry-ditch crossings, complete streambed and bank 

stabilization before returning flow to the waterbody channel. 

 

3. Return all waterbody banks to preconstruction contours or to a stable 

angle of repose as approved by the Environmental Inspector. 

4. Application of riprap for bank stabilization must comply with COE, or its 

delegated agency, permit terms and conditions. 

5. Unless otherwise specified by state permit, limit the use of riprap to areas 

where flow conditions preclude effective vegetative stabilization 

techniques such as seeding and erosion control fabric or flexible channel 

liners.

6. Revegetate disturbed riparian areas with conservation grasses and legumes 

or native plant species, preferably woody species. 

7. Install a permanent slope breaker across the construction right-of-way at 

the base of slopes greater than 5 percent that are less than 50 feet from the 

waterbody, or as needed to prevent sediment transport into the waterbody. 

In addition, install sediment barriers as outlined in the Plan. In some 

areas, with the approval of the Environmental Inspector, an earthen berm 

may be suitable as a sediment barrier adjacent to the waterbody. 

8. Sections V.C.3. through V.C.6. above also apply to those perennial or 

intermittent streams not flowing at the time of construction. 

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D. POST-CONSTRUCTION MAINTENANCE 

1. Along the Natural Gas System Interconnections only, limit vegetation 

maintenance adjacent to waterbodies to allow a riparian strip at least 25 

feet wide, as measured from the waterbody's mean high water mark, to 

permanently revegetate with native plant species across the entire 

construction right-of-way. However, to facilitate periodic pipeline 

corrosion/leak surveys, a corridor centered on the pipeline and up to 10 

feet wide may be maintained in a herbaceous state. In addition, trees that 

are located within 15 feet of the pipeline that are greater than 15 feet in 

height may be cut and removed from the permanent right-of-way. 

2. Do not use herbicides or pesticides in or within 100 feet of a waterbody 

except as allowed by the appropriate land management or state agency. 

VI. WETLAND CROSSINGS 

A. GENERAL 

1. The project sponsor shall conduct a wetland delineation using the current 

Federal methodology and file a wetland delineation report with the 

Secretary before construction. This report shall identify: 

a. by milepost all wetlands that would be affected;

b. the National Wetlands Inventory (NWI) classification for each 

wetland; 

c. the crossing length of each wetland in feet; and 

d. the area of permanent and temporary disturbance that would occur 

in each wetland by NWI classification type. 

The requirements outlined in this section do not apply to wetlands in 

actively cultivated or rotated cropland. Standard upland protective 

measures, including workspace and topsoiling requirements, apply to these 

agricultural wetlands. 

2. Route the pipeline to avoid wetland areas to the maximum extent possible. 

If a wetland cannot be avoided or crossed by following an existing rightof-way, route the new pipeline in a manner that minimizes disturbance to 

wetlands. Where looping an existing pipeline, overlap the existing 

pipeline right-of-way with the new construction right-of-way. In addition, 

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locate the loop line no more than 25 feet away from the existing pipeline 

unless site-specific constraints would adversely affect the stability of the 

existing pipeline. 

3. Limit the width of the construction right-of-way to 75 feet or less. Prior 

written approval of the Director is required where topographic conditions 

or soil limitations require that the construction right-of-way width within 

the boundaries of a federally delineated wetland be expanded beyond 75 

feet. Early in the planning process the project sponsor is encouraged to 

identify site-specific areas where existing soils lack adequate unconfined 

compressive strength that would result in excessively wide ditches and/or 

difficult to contain spoil piles. Bayou Casotte Energy is proposing a 

nominal construction right-of-way of 110 feet in several locations along 

the pipeline route. The soils expected along the pipeline route are 

predominately poorly drained mucky sandy clay loam that is frequently 

flooded. Moreover, the water table is typically very close to the surface. 

These conditions will adversely affect the slope and stability of the 

excavation and indicate greater than normal excavation (ditch) widths 

and spoil volume. In addition to these complications, an expanded 

construction right-of-way is needed due to the containment of a dual 

pipeline configuration.

 

4. For those Project areas utilized via an easement agreement only, 

wetland boundaries and buffers must be clearly marked in the field with 

signs and/or highly visible flagging until construction-related ground 

disturbing activities are complete. 

5. Implement the measures of sections V. and VI. in the event a waterbody 

crossing is located within or adjacent to a wetland crossing. If all 

measures of sections V. and VI. cannot be met, the project sponsor must 

file with the Secretary a site-specific crossing plan for review and written 

approval by the Director before construction. This crossing plan shall 

address at a minimum: 

a. spoil control; 

b. equipment bridges; 

c. restoration of waterbody banks and wetland hydrology; 

d. timing of the waterbody crossing; 

e. method of crossing; and 

f. size and location of all extra work areas. 

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6. For those Project areas utilized via an easement agreement only, do not 

locate aboveground facilities in any wetland, except where the location of 

such facilities outside of wetlands would prohibit compliance with U.S. 

Department of Transportation regulations. 

B. INSTALLATION 

1. Extra Work Areas and Access Roads 

a. For those Project areas utilized via an easement agreement only, 

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. 

 

b. For those Project areas utilized via an easement agreement only, 

the project sponsor shall file with the Secretary for review and 

written approval by the Director, a site-specific construction plan 

for each extra work area with a less than 50-foot setback from 

wetland boundaries (except where adjacent upland consists of 

actively cultivated or rotated cropland or other disturbed land) and 

a site-specific explanation of the conditions that will not permit a 

50-foot setback. 

c. Limit clearing of vegetation between extra work areas and the edge 

of the wetland to the certificated construction right-of-way. 

d. The construction right-of-way may be used for access when the 

wetland soil is firm enough to avoid rutting or the construction 

right-of-way has been appropriately stabilized to avoid rutting 

(e.g., with timber riprap, prefabricated equipment mats, terra mats). 

In wetlands that cannot be appropriately stabilized, all construction 

equipment other than that needed to install the wetland crossing 

shall use access roads located in upland areas. Where access roads 

in upland areas do not provide reasonable access, limit all other 

construction equipment to one pass through the wetland using the 

construction right-of-way. 

Bayou Casotte Energy is proposing the use of three techniques to 

construct wetland crossings. The three include: 

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 Method I Dry or Moist Wetlands 

This method will typically apply to the crossing of a Type I 

wetland. A Type I wetland typically has groundwater level 

existing some depth below the surface. Equipment can traverse 

the wetland without the support of mats and trench excavations 

are stable. Topsoil will be segregated. Pipe stringing and 

fabrication may occur within the wetland adjacent to the trench 

line or adjacent to the wetland in a designated extra workspace. 

 Method II Saturated, Wetland Crossing

This method will apply to the crossing of a Type II wetland. 

Soils are saturated and non-cohesive. Difficult trenching, 

conditions are likely, and trench widths of up to 35 feet are 

common. In these wetland types, supplemental support in the 

form of timber rip-rap or prefabricated equipment mats is 

required. Topsoil stripping is impractical due to the nature of 

the soil. Pipe stringing and fabrication may occur within the 

wetland adjacent to the trench line or adjacent to the wetland in 

a designated extra workspace. 

 Method III Partially/Completely Flooded Wetland

In these wetlands, standing surface water or high groundwater 

levels are present. Difficult trenching conditions may exist, and 

trench widths of up to 35 feet are common. Topsoil stripping is 

impossible due to the flooded conditions. Pipe stringing and 

fabrication may take place within the wetland adjacent to the 

trench line or adjacent to the wetland in a designated extra 

workspace.

e. The only access roads, other than the construction right-of-way, 

that can be used in wetlands without Director approval, are those 

existing roads that can be used with no modification and no impact 

on the wetland. 

2. Crossing Procedures 

a. Comply with COE, or its delegated agency, permit terms and 

conditions 

b. Assemble the pipeline in an upland area unless the wetland is dry 

enough to adequately support skids and pipe. 

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c. In Type III wetlands use "push-pull" or "float" techniques to place 

the pipe in the trench where water and other site conditions allow. 

d. Minimize the length of time that topsoil is segregated and the 

trench is open. 

e. Limit construction equipment operating in Type II and Type III

wetland areas to that needed 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. 

f. Cut vegetation just aboveground level, leaving existing root 

systems in place, and remove it from the wetland for disposal. 

g. Limit pulling of tree stumps and grading activities to directly over 

the trenchline. Do not grade or remove stumps or root systems 

from the rest of the construction right-of-way in wetlands unless 

the Chief Inspector and Environmental Inspector determine that 

safety-related construction constraints require grading or the 

removal of tree stumps from under the working side of the 

construction right-of-way. 

h. Segregate the top 1 foot of topsoil from the area disturbed by 

trenching in Type I wetlands, except in areas where standing water 

is present or soils are saturated or frozen. Immediately after 

backfilling is complete, restore the segregated topsoil to its 

original location. 

i. Do not use rock, soil imported from outside the wetland, tree 

stumps, or brush riprap to support equipment on the construction 

right-of-way. 

j. If standing water or saturated soils are present, or if construction 

equipment causes ruts or mixing of the topsoil and subsoil in 

wetlands, use low-ground-weight construction equipment, or 

operate normal equipment on timber riprap, prefabricated 

equipment mats, or terra mats. 

k. Do not cut trees outside of the approved construction work area to 

obtain timber for riprap or equipment mats.

l. Attempt to use no more than two layers of timber riprap to support 

equipment on the construction right-of-way. 

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m. Remove all project-related material used to support equipment on 

the construction right-of-way upon completion of construction. 

3. Temporary Sediment Control 

Install sediment barriers (as defined in section IV.F.2.a. of the Plan) 

immediately after initial disturbance of the wetland or adjacent upland. 

Sediment barriers must be properly maintained throughout construction 

and reinstalled as necessary (such as after backfilling of the trench). 

Except as noted below in section VI.B.3.c., maintain sediment barriers 

until replaced by permanent erosion controls or restoration of adjacent 

upland areas is complete. Temporary erosion and sediment control 

measures are addressed in more detail in the Plan. 

a. Install sediment barriers across the entire construction right-of-way 

at all wetland crossings where necessary to prevent sediment flow 

into the wetland. In the travel lane, these may consist of 

removable sediment barriers or drivable berms. Removable 

sediment barriers can be removed during the construction day, but 

must be re-installed after construction has stopped for the day 

and/or when heavy precipitation is imminent 

b. Where wetlands are adjacent to the construction right-of-way and 

the right-of-way slopes toward the wetland, install sediment 

barriers along the edge of the construction right-of-way as 

necessary to prevent sediment flow into the wetland. 

c. Install sediment barriers along the downslope edge of the 

construction right-of-way as necessary to contain spoil and 

sediment within the construction right-of-way through wetlands. 

Remove these sediment barriers during right-of-way cleanup. 

4. Trench Dewatering 

Dewater the trench (either on or off the construction right-of-way) in a 

manner that does not cause erosion and does not result in heavily silt-laden 

water flowing into any wetland. Remove the dewatering structures as 

soon as possible after the completion of dewatering activities. 

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C. RESTORATION 

1. Where the pipeline trench may drain a wetland, construct trench breakers 

and/or seal the trench bottom as necessary to maintain the original wetland 

hydrology. 

2. For each wetland crossed, install a trench breaker at the base of slopes 

near the boundary between the wetland and adjacent upland areas. Install 

a permanent slope breaker across the construction right-of-way at the base 

of slopes greater than 5 percent where the base of the slope is less than 50 

feet from the wetland, or as needed to prevent sediment transport into the 

wetland. In addition, install sediment barriers as outlined in the Plan. In 

some areas, with the approval of the Environmental Inspector, an earthen 

berm may be suitable as a sediment barrier adjacent to the wetland. 

3. Do not use fertilizer, lime, or mulch unless required in writing by the 

appropriate land management or state agency. 

4. Consult with the appropriate land management or state agency to develop 

a project-specific wetland restoration plan. The restoration plan should 

include measures for re-establishing herbaceous and/or woody species, 

controlling the invasion and spread of undesirable exotic species (e.g., 

purple loosestrife and phragmites), and monitoring the success of the 

revegetation and weed control efforts. Provide this plan to the FERC staff 

upon request. 

5. Until a project-specific wetland restoration plan is developed and/or 

implemented, temporarily revegetate the construction right-of-way with 

annual ryegrass at a rate of 40 pounds/acre (unless standing water is 

present). 

6. Ensure that all disturbed areas successfully revegetate with wetland 

herbaceous and/or woody plant species. 

7. Remove temporary sediment barriers located at the boundary between 

wetland and adjacent upland areas after upland revegetation and 

stabilization of adjacent upland areas are judged to be successful as 

specified in section VII.A.5. of the Plan. 

D. POST-CONSTRUCTION MAINTENANCE 

1. Do not conduct vegetation maintenance over the full width of the 

permanent right-of-way in wetlands. However, to facilitate periodic 

pipeline corrosion/leak surveys, a corridor centered on the pipeline and up 

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to 10 feet wide may be maintained in an herbaceous state. In addition, 

trees within 15 feet of the pipeline that are greater than 15 feet in height 

may be selectively cut and removed from the permanent right-of-way. 

2. Do not use herbicides or pesticides in or within 100 feet of a wetland, 

except as allowed by the appropriate land management agency or state 

agency. 

3. Monitor and record the success of wetland revegetation annually for the 

first 3 years after construction or until wetland revegetation is successful,

except in circumstances where property is purchased and developed or 

until revegetation is deemed successful. At the end of 3 years after 

construction, file a report with the Secretary identifying the status of the 

wetland revegetation efforts. Include the percent cover achieved and 

problem areas (weed invasion issues, poor revegetation, etc.). Continue to 

file a report annually until wetland revegetation is successful. 

4. Wetland revegetation shall be considered successful if the cover of 

herbaceous and/or woody species is at least 80 percent of the type, density, 

and distribution of the vegetation in adjacent wetland areas that were not 

disturbed by construction. If revegetation is not successful at the end of 3 

years, develop and implement (in consultation with a professional wetland 

ecologist) a remedial revegetation plan to actively revegetate the wetland. 

Continue revegetation efforts until wetland revegetation is successful. 

VII. HYDROSTATIC TESTING 

A. NOTIFICATION PROCEDURES AND PERMITS 

1. Apply for state-issued water withdrawal permits, as required. 

2. Apply for National Pollutant Discharge Elimination System (NPDES) or 

state-issued discharge permits, as required. 

3. Notify appropriate state agencies of intent to use specific sources at least 

48 hours before testing activities unless they waive this requirement in 

writing. 

B. GENERAL 

1. Perform non-destructive testing of all pipeline section welds or hydrotest 

the pipeline sections, before installation under waterbodies or wetlands. 

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2. If pumps used for hydrostatic testing are within 100 feet of any waterbody 

or wetland, address the operation and refueling of these pumps in the 

project’s Spill Prevention and Response Procedures. 

3. The project sponsor shall file with the Secretary before construction a list 

identifying the location of all waterbodies proposed for use as a 

hydrostatic test water source or discharge location. 

C. INTAKE SOURCE AND RATE 

1. Screen the intake hose to prevent entrainment of fish. 

2. Do not use state-designated exceptional value waters, waterbodies which 

provide habitat for federally listed threatened or endangered species, or 

waterbodies designated as public water supplies, unless appropriate 

Federal, state, and/or local permitting agencies grant written permission. 

3. Maintain adequate flow rates to protect aquatic life, provide for all 

waterbody uses, and provide for downstream withdrawals of water by 

existing users. 

4. Locate hydrostatic test manifolds outside wetlands and riparian areas to 

the maximum extent practicable. 

D. DISCHARGE LOCATION, METHOD, AND RATE 

1. Regulate discharge rate, use energy dissipation device(s), and install 

sediment barriers, as necessary, to prevent erosion, streambed scour, 

suspension of sediments, or excessive streamflow. 

2. Do not discharge into state-designated exceptional value waters, 

waterbodies which provide habitat for federally listed threatened or 

endangered species, or waterbodies designated as public water supplies, 

unless appropriate Federal, state, and local permitting agencies grant 

written permission. 

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VARIANCES DETAILED DISCUSSION 

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1. Section III.A. 

Add – “...(a “spread” is defined herein as both the Terminal and the Natural Gas 

System Interconnections)...” 

Due to the point-source and slower-paced nature of LNG terminal construction and the short 

length of the Natural Gas System Interconnections, Bayou Casotte Energy anticipates that one 

(1) Environmental Inspector shall suffice for the Project. 

2. Section IV.A.1.d., e., and f. 

Add – “for those Project areas utilized via an easement agreement only,...” 

The construction of the Terminal will involve the permanent filling and loss of wetland resource 

areas within the site. These measures are not applicable. 

3. Section V.B.2.a., b., V.B.3.f., V.B.4.a., VI.A.4., 6., and VI.B.1.a. and b. 

 Add – “For those Project areas utilized via an easement agreement only,...” 

The construction of the Terminal will involve the permanent filling and loss of wetland resource 

areas within the site. These measures are not applicable. 

4. Section V.B.5.b.(1) 

Add – “...where culverts are necessary to support the equipment pads;” 

This will allow small, well defined channels to be spanned by a single set of equipment pads 

only, with no installation of a culvert while negating or minimizing environmental impacts to the 

stream.

5. Section V.B.5.b.(4) 

Add – “...or salvaged flat bed rail cars or equivalent.” 

Bayou Casotte Energy proposes to ad salvage flat bed rail cars because they may be more readily 

available to contractors while still providing the same level of environmental protection.

6. Section V.B.5.c. 

Modify – “Design and maintain each equipment bridge to accommodate the highest flow 

expected to occur while the bridge is in place as determined by historical records for the 

expected construction period or by an engineer in consultation with applicable state agencies 

and the USACE.” 

It is not reasonable to design the bridge or other conveyance to withstand the largest flow 

possible. Historical data and/or engineering design criteria exist which provide guidance for the 

appropriate design flow given the length of time and season of installation. The utilization of an 

engineer or consultation with the applicable state agencies or the USACE will enable the 

equipment bridge to be designed for the site-specific conditions.

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7. Section V.B.8.a. 

 Add – “...(i.e., local noise ordinances, etc.)...” 

There may be conditions, such as noise ordinances, which make the completion of the crossing 

within 48 hours infeasible; however the crossing will be completed as soon as practicable. 

8. Section V.B.10.a. 

 Add – “...with provisions to access any equipment bridges present...” 

Bayou Casotte Energy proposes that access gaps be installed and opened only when work is in 

progress within the area and to allow for access into the work area. Silt fence and straw bale 

barriers will be used to close the gaps upon completion of the daily work and during a rain event. 

Silt Fencing and hay bales will be regularly inspected, maintained and replaced when needed. 

9. Section V.C.5. 

Add – “...or flexible channel liners.” 

Liners used for channel restoration must be capable of withstanding tractive forces caused by 

channelized flow. The industry term for such liners is “flexible channel liners”. Pre-seeded 

liners are not typically used since it is often difficult to obtain optimum seed mixes and success 

is generally poor. Experience shows that the use of the flexible channel liners will provide better 

environmental protection than pre-seeded liners. 

10. Section V.D.1. 

Add – “Along the Natural Gas System Interconnections only...” 

Due to the nature of LNG terminal grounds maintenance, this section shall only apply to the 

Natural Gas System Interconnections. 

11. Section VI.A.3. 

Add – “Bayou Casotte Energy is proposing a nominal construction right-of-way of 110 

feet in several locations along the pipeline route. The soils expected along the pipeline route 

are predominately poorly drained mucky sandy clay loam that is frequently flooded. 

Moreover, the water table is typically very close to the surface. These conditions will adversely 

affect the slope and stability of the excavation and indicate greater than normal excavation 

(ditch) widths and spoil volume. In addition to these complications, an expanded construction 

right-of-way is needed due to the containment of a dual pipeline configuration.” 

Adequate workspace is the single greatest factor controlling the efficiency of pipeline 

construction with respect to time, environmental impact, and cost. Bayou Casotte Energy 

expended considerable effort in the development of what it considers the optimum construction

right-of-way width for the Natural Gas System Interconnections. This width was determined 

based on the recommendations outlined in the FERC Plan and Procedures, the collective 

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experience of pipeline construction in southern Mississippi, and the conditions expected on this 

Project. 

The construction right-of-way width requested is based on the experience of the Bayou Casotte 

Energy team, field inspections and the knowledge of the subsoil profile. 

SSURGO database information and other publicly available sources were used by Bayou 

Casotte Energy to confirm the probable soils that will be encountered along the proposed 

pipeline route. These sources contain valuable information regarding soils and their general 

properties, and support Bayou Casotte Energy’s position that the excavations will be difficult. 

The proposed pipeline corridor associated with the Natural Gas Systems Interconnections 

traverses essentially flat coastal plain terrains. The subsoil profile expected involves 

predominantly non-cohesive material with a relatively high water table. The soils are 

predominately poorly drained mucky sandy clay loam that is frequently flooded that typically 

exhibit loose density. Under these soil conditions, unstable excavations and dewatering 

problems would be encountered by any construction, which involves earth moving. Unstable 

soils for the purposes of this discussion refer to soils that present instabilities during 

construction and not to long-term instabilities that would affect the integrity of the installed 

pipeline. 

The length of time an excavation is open is of critical importance in these types of soils. 

Wetting-drying cycles will cause changes in the strength of granular soils; the longer an 

excavation is left open the more likely it may become unstable. Granular soils are also 

susceptible to shock and vibration resulting from working equipment, pile driving, etc. This is 

another factor why the right-of-way width as requested by Bayou Casotte Energy is necessary. 

Decreased construction right-of-way width will slow down the progress resulting in increased 

excavation time. This will lead to the increased potential for sloughing in the ditch. 

Unless some kind of support is provided, the soils encountered will lead to wide trench and borepit excavations, and extensive dewatering.

In general, due to the fine grained nature of the mucky sandy clay loam, low permeabilities are 

expected. As a result, drainage may not be immediate and unstable rapid draw-down conditions 

may occur if there are rapid differences in water elevations between the trench and the 

surrounding natural terrain. Also, local liquefaction may occur as a result of vibrations, spoil 

damping, or other sudden loading. 

Slope stability analysis indicates failures may occur that would involve the adjacent spoil, unless 

the edge of the mound is kept at a minimum distance on the order of seven feet from the edge of 

the trench. It must be kept in mind that any slide involves an extra volume to be removed to 

clear the trench; such extra volume would require additional workspace and might trigger new 

slides if simply dumped on top of the existing spoil. 

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All of the conditions listed will adversely affect the slope and stability of the excavation and 

indicate greater than normal excavation (ditch) widths and spoil volumes. 

12. Section VI.B.1.d. 

Add – “Bayou Casotte Energy is proposing the use of three techniques to affect wetland 

crossing. The three include: 

Method I Dry or Moist Wetlands 

This method will typically apply to the crossing of a Type I wetland. A Type I wetland typically 

has groundwater level existing some depth below the surface. Equipment can traverse the 

wetland without the support of mats and trench excavations are stable. Topsoil will be 

segregated. Pipe stringing and fabrication may occur within the wetland adjacent to the 

trench line or adjacent to the wetland in a designated extra workspace. 

Method II Saturated, Wetland Crossing

This method will apply to the crossing of a Type II wetland. Soils are saturated and noncohesive. Difficult trenching, conditions are likely, and trench widths of up to 35 feet are 

common. In these wetland types, supplemental support in the form of timber rip-rap or 

prefabricated equipment mats is required. Topsoil stripping is impractical due to the nature of 

the soil. Pipe stringing and fabrication may occur within the wetland adjacent to the trench 

line or adjacent to the wetland in a designated extra workspace. 

Method III Partially/Completely Flooded Wetland

In these wetlands, standing surface water or high groundwater levels are present. Difficult 

trenching conditions may exist, and trench widths of up to 35 feet are common. Topsoil 

stripping is impossible due to the flooded conditions. Pipe stringing and fabrication may take 

place within the wetland adjacent to the trench line or adjacent to the wetland in a designated 

extra workspace.” 

The type of wetlands crossed will dictate the necessary stabilization methods. Defining the types 

of wetlands will make the crossing requirements more defined for the contractor while still 

providing the environmental protection the Commission requires. 

13. Section VI.B.2.c. 

 Add – “In Type III wetlands..." 

It is not necessary to use the “push-pull” or “float” techniques in all wetlands, only those that are 

considered flooded and where there is enough water to do so. 

14. Section VI.B.2.e. 

Add – “...Type II and Type III...” 

In Type 1 wetlands, which are considered dry wetlands, equipment can traverse the wetland 

without the support of mats and continue the construction spread through the wetland; the soils 

are unsaturated. 

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15. Section VI.B.2.h. 

Add – “...Type I wetlands...” 

The soils in Type II and Type III wetlands are too saturated for the topsoil to be segregated. 

16. Section VI.B.3.c. 

Add – “...downslope...” 

Placing the sediment barriers along the downslope edge of the construction right-of-way will 

provide the necessary environmental protection to the wetland. 

17. Section VI.D.3. 

Add – “...except in circumstances where property is purchased and developed or until 

revegetation is deemed successful.” 

If the property containing a wetland is sold and developed, Bayou Casotte Energy should no 

longer be required to monitor that wetland. If revegetation is established earlier than 3 years, 

Bayou Casotte Energy will not be required to monitor the wetland.

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FIGURES 

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX C 

STORMWATER POLLUTION PREVENTION PLAN 

FOR CONSTRUCTION ACTIVITIES 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
STORM WATER POLLUTION 

PREVENTION PLAN (SWPPP) FOR 

CONSTRUCTION ACTIVITIES 

FOR 

BAYOU CASOTTE ENERGY LLC 

CASOTTE LANDING NATURAL GAS 

IMPORT TERMINAL 

PASCAGOULA, MISSISSIPPI 

Bayou Casotte Energy LLC 

Casotte Landing Natural Gas Import Terminal 

Address To Be Established 

Pascagoula, Mississippi, 39567 

January 2006 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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 Import Terminal Project

Casotte Landing Natural Gas Draft Storm Water Pollution 

 Import Terminal Project Prevention Plan

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LIST OF ACRONYMS 

BMPs Best Management Practices 

CFR Code of Federal Regulations 

CUSA Chevron U.S.A. 

DOT Department of Transportation 

EPA Environmental Protection Agency 

ERP Emergency Response Plan 

FERC Federal Energy Reserve Commission 

LNG Liquefied Natural Gas 

MDEQ Mississippi Department of Environmental Quality 

MSDS Material Safety Data Sheets 

N/A Not Applicable 

NOI Notice of Intent 

NOT Notice of Termination 

NPDES National Pollutant Discharge Elimination System 

SWPPP Storm Water Pollution Prevention Plan 

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RECORD OF REVISIONS 

Revision 

No. 

Revision 

Date 

Description of Revision Replaced 

Page(s) 

 

 

 

 

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OWNER’S CERTIFICATION 

“I certify under penalty of law that this document and all attachments were prepared 

under my direction or supervision in accordance with a system designed to assure that 

qualified personnel properly gathered and evaluated the information submitted. Based 

on my inquiry of the person or persons who manage the system, or those persons 

directly responsible for gathering the information, the information submitted is, to the 

best of my knowledge and belief, true, accurate and complete. I am aware that there are 

significant penalties for submitting false information, including the possibility of fine and 

imprisonment for knowing violations.” 

Company:_____________________________ 

Signed:_______________________________ 

Printed Name:_______________________________ 

Title:_______________________________ 

Date:_______________________________ 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Table of Contents (cont.) 

Casotte Landing Natural Gas Draft Storm Water Pollution 

 Import Terminal Project Prevention Plan

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Section Page No. 

LIST OF ACRONYMS............................................................................................................. 1

RECORD OF REVISIONS ...................................................................................................... 2

OWNER’S CERTIFICATION................................................................................................... 3

A. SCOPE............................................................................................................................ 6

B. GENERAL INFORMATION ............................................................................................ 6

B.1. PROJECT OWNER AND OPERATOR.................................................................. 6

B.2. PROJECT CONTACT INFORMATION.................................................................. 6

B.3. PROJECT LOCATION........................................................................................... 6

B.4. RECEIVING WATER BODY FOR STORM WATER DISCHARGES ..................... 6

B.5. POTENTIAL SOURCES OF POLLUTION AT THE PROJECT SITE..................... 6

C. SITE DESCRIPTION....................................................................................................... 7

C.1. PROPOSED PROJECT DESCRIPTION ............................................................... 7

C.2. REGULATORY BASIS........................................................................................... 7

C.3. IMPLEMENTATION PRIOR TO CONSTRUCTION............................................... 7

C.4. CONSTRUCTION SCHEDULE ........................................................................... 10

C.5. SOILS DESCRIPTION......................................................................................... 14

C.6. STORMWATER RUNOFF AND RECEIVING WATERS ..................................... 14

D. SEDIMENTATION AND EROSION CONTROLS......................................................... 14

D.1. EROSION AND SEDIMENT CONTROLS CRITERIA.......................................... 15

D.2. STRUCTURAL PRACTICES ............................................................................... 16

D.3. STABILIZATION PRACTICES............................................................................. 17

E. OTHER POLLUTION CONTROLS............................................................................... 19

E.1. CHEMICAL STORAGE AREA ............................................................................. 19

E.2. FUELING AND MAINTENANCE AREA............................................................... 20

E.3 WASTE STORAGE AREA................................................................................... 20

F. APPROVED STATE, TRIBAL OR LOCAL PLANS..................................................... 20

G. MAINTENANCE............................................................................................................ 20

H. INSPECTIONS.............................................................................................................. 21

H.1. CONSTRUCTION INSPECTION RESPONSIBILITIES....................................... 21

H.2. POST CONSTRUCTION INSPECTION RESPONSIBILITIES ............................ 22

H.3. INSPECTION DOCUMENTATION ...................................................................... 22

H.4. RETENTION OF RECORDS ............................................................................... 22

I. NON-STORM WATER DISCHARGES......................................................................... 23

I.1. HYDROSTATIC TESTING................................................................................... 23

J. PROPER OPERATIONS AND MAINTENANCE.......................................................... 23

K. SPILL PREVENTION.................................................................................................... 23

K.1. GOOD HOUSEKEEPING .................................................................................... 24

K.2 HAZARDOUS PRODUCTS ................................................................................. 24

K.3 PRODUCT SPECIFIC PRACTICES .................................................................... 24

L. TRAINING ..................................................................................................................... 25

M. TERMINATION OF PERMIT COVERAGE................................................................... 25

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Table of Contents (cont.) 

Casotte Landing Natural Gas Draft Storm Water Pollution 

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Figures 

TO BE ADDED PRIOR TO COMMENCEMENT OF CONSTRUCTION 

ACTIVITIES

Figure 1 Project Location 

Figure 2 Site Storm Drainage Plan 

 (Available in Volume IV, Figure 1.5.2.1-3) 

Attachments 

TO BE ADDED PRIOR TO COMMENCEMENT OF CONSTRUCTION 

ACTIVITIES

 Attachment 1 U.S.G.S. 7.5 Minute Quadrangle Topographic 

Site Map and Arial Photograph Jackson 

County 

 Attachment 2 Notice of Intent (NOI), NPDES Permit, and 

Notice of Termination (NOT) of Coverage 

 Attachment 3 Inspection Forms 

- Daily Inspection Form/Litter Control 

Checklist 

- General Site Control/Post-Storm Checklist 

- MDEQ Inspection and Certification Form 

- MDEQ Inspection Suspension Form 

- Bayou Casotte Energy Post Construction 

Inspection Report Stabilization Monitoring 

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 Import Terminal Project Prevention Plan

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A. SCOPE 

This Storm Water Pollution Prevention Plan (SWPPP) prescribes requirements for 

identifying potential pollution sources and establishing Best Management Practices 

(BMPs) which include sediment, erosion and other controls, stabilization and structural 

practices, stormwater management, proper operations and maintenance, and 

inspections for the construction project described herein. 

B. GENERAL INFORMATION 

B.1. PROJECT OWNER AND OPERATOR 

 Bayou Casotte Energy LLC, a subsidiary of Chevron U.S.A. 

 1500 Louisiana Street 

 Houston, Texas 77002 

B.2. PROJECT CONTACT INFORMATION 

 

 Company: Bayou Casotte Energy LLC 

 Name of contact: Michael J. De Nicola 

 Office Telephone: 832-854-6228 

 Cellular Telephone: 713-560-2235 

Fax Number: 832-854-6283 

B.3. PROJECT LOCATION 

Bayou Casotte, Jackson County, Mississippi 

B.4. RECEIVING WATER BODY FOR STORM WATER DISCHARGES 

Bayou Casotte Channel 

B.5. POTENTIAL SOURCES OF POLLUTION AT THE PROJECT SITE 

Sediment from land disturbances; construction debris and trash; minor 

petroleum leaks from construction equipment. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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C. SITE DESCRIPTION 

C.1. PROPOSED PROJECT DESCRIPTION 

Bayou Casotte Energy proposes to build and operate an onshore liquefied 

natural gas (LNG) import terminal and associated facilities (Terminal) south of 

the existing Chevron U.S.A. (CUSA) Pascagoula Refinery (Pascagoula Refinery) 

on Bayou Casotte, just east of Pascagoula, Mississippi, in Jackson County. The 

proposed Casotte Landing Natural Gas Import Terminal Project (Casotte 

Landing, Project, or Terminal) includes construction of a slip and berth for 

offloading LNG carriers, relocation of existing Refinery Berths 6 and 7, and 

construction of facilities to receive and regasify LNG for transport into nearby 

existing United States (U.S.) natural gas transmission grid. 

C.2. REGULATORY BASIS 

The state of Mississippi has been authorized by the U.S. Environmental 

Protection Agency to issue National Pollutant Discharge Elimination System 

(NPDES) permit coverage for storm water discharges to surface waters of the 

state. The Mississippi Department of Environmental Quality (MDEQ) is the 

regulatory agency that issues permit coverage under the NPDES program for the 

state of Mississippi. On June 10, 2005, MDEQ issued NPDES General Permit 

No. MSR10 for the discharge of storm water from construction sites for land 

disturbing activities of 5 acres or more located within the state of Mississippi. 

 Issuance of permit coverage is conditional upon payment of applicable fees, 

 completion and certification of an applicable SWPPP for the construction site, 

 and submittal of a completed Notice of Intent (NOI) application form. 

 Authorization to discharge storm water from construction activities under the 

 terms and conditions of the NPDES general permit is granted two (2) days after 

 the date the completed NOI is postmarked. A NPDES Storm Water General 

 Permit for Construction Activities in Region 4, a copy of the permit NOI is 

 attached (see Attachment 2). 

C.3. IMPLEMENTATION PRIOR TO CONSTRUCTION 

The SWPPP must be prepared and implemented prior to the commencement of 

site modifications. Therefore, upon determination of the construction contractor, 

this SWPPP will be finalized and certified prior to the commencement of 

construction activities. 

The site operator shall ensure that individuals responsible for the implementation, 

maintenance and inspection of all BMPs prescribed in this SWPPP have been 

trained in the proper function and maintenance of storm water pollution 

prevention controls. The prescribed sedimentation and erosion controls for the 

site modifications will be constructed or installed prior to land disturbing activities. 

The site operator will administer the practices stated in this SWPPP as well as 

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 Import Terminal Project

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requirements detailed in the NPDES general permit until site modifications are 

complete. 

 If anticipated conditions or BMPs change during site modifications, it will be 

 necessary to revise this SWPPP to accurately reflect the conditions and 

controls in use at the site. The Record of Revisions page (Page 1) shall be 

utilized for and revisions made to the SWPPP following the initial certification. 

 The following pre-construction activities will be implemented prior to beginning 

 the construction schedule, as described in C.4. 

1. Obtain applicable permits and plan approval. 

2. Conduct a pre-construction conference prior to starting work including 

Bayou Casotte Energy’s Construction Manager, construction inspector 

(trained for environmental inspection), and contractors. 

3. Install erosion control measures and practices prior to or concurrent with 

commencement of land disturbing activities, including construction 

entrances and exits, silt fences, interceptor dikes, temporary culverts (if 

needed), and temporary wetland and waterbody crossings, as indicated in 

this Stormwater Pollution Prevention Plan (SWPPP). 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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 Import Terminal Project

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Insert Figure 1 Project Location 

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 Import Terminal Project

Casotte Landing Natural Gas Draft Storm Water Pollution 

 Import Terminal Project Prevention Plan

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C.4. CONSTRUCTION SCHEDULE 

The schedule of major construction activities are listed below. The schedule reflects 

three key areas: 1) the Onshore LNG Storage Facilities, which defines the critical path 

of the schedule; 2) the Marine Facilities; and 3) the Vaporization Facilities. 

1.) Onshore LNG Storage Facilities – Duration: 35 Months 

 A.) Preliminaries – Duration: 9 Months 

 1. Site Layout – temporary on-site facilities required for construction 

 of the Project components. Included in the plan are: 

• Contractor office/change/tool trailer area; 

• Construction parking; 

• Workshop/pre-assembly areas; 

• On-site concrete batching plant; and 

• Material laydown areas. 

2. Excavation Depth – some below grade excavations will be 

 required – these excavations are typically ten feet or less, except 

 for the LNG spill impoundment basins. The following excavations 

 are anticipated for the various facilities of the Project: 

• Miscellaneous footings; 

• LNG spill impoundment basin (approx. 30 ft. below finished 

 Terminal grade); 

• LNG unloading lines; 

• Cooling lines (in part); and 

• Firewater piping and firewater piping loop around the 

 process area will be installed underground. 

3. Existing structure demolition 

• Existing buildings and concrete structures; 

• Existing Berth #7; 

• Topside demolition; and 

• Berth structure demolition. 

B.) Prefabrication – Storage Tank Duration: 22 Months 

C.) Materials and Equipment Delivery – Duration: 25 Months 

 Materials and equipment procured offshore will be shipped from the 

place of origin to an appropriate local port (Pascagoula, Mobile, or New 

Orleans) and either unloaded (if final transportation to site will be 

undertaken by road) or trans-shipped onto barges (if the equipment or 

materials will be delivered to the Terminal site via marine transport). 

D.) LNG Storage Tanks Construction – Duration: 25 Months 

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• The tank area will be filled, consolidated, and graded to the 

required level for the piling operations to be undertaken. 

• Piles will be installed in accordance with a specific 

predetermined sequence. 

E.) Construction of other Facilities – foundations, pipe racks, Terminal 

 buildings, electrical and mechanical equipment — Duration: 19 months 

F.) Hydrotesting and Pneumatic Testing of the LNG Storage Tanks and 

 Pipework — Duration: 2 months 

G) Restoration – final grading, erosion control — Duration: 11 months 

Areas of property disturbed by construction of the proposed facilities will 

be stabilized with temporary erosion controls until construction is 

complete. Unless covered by equipment, gravel or other covering, 

Terminal site areas will be seeded to establish a grass cover in 

compliance with the FERC Upland Erosion Control, Revegetation and 

Maintenance Plan (Plan) and Wetland and Waterbody Construction and 

Mitigation Procedures (Procedures) and project specifications. 

2.) Marine Facilities — Duration: 21 months 

 A.) Sequence 1, Duration: 7.5 months 

• Remove existing foundations and underground structures within proposed 

slip area. 

• Drive piles for trestle, unloading platform, and breasting/mooring dolphins 

for New Berth #6. Work shall proceed outward from shore to minimize 

disruption of Crude Berth #6 and #7 operations. 

• Construct trestle and unloading platform for New Berth #6. 

• Build earthen dam or install temporary sheet pile wall between area to be 

excavated and Bayou Casotte. 

• Install temporary sheet pile wall on south and east side of Berth #7 

trestle. 

• Excavate down to water table with land-based equipment. 

 B.) Sequence 2, Duration: 3.5 months 

• Construct breasting and mooring dolphins for New Berth #6. Install piping 

and topside equipment. 

• Remove portion of earthen dam or temporary sheet pile wall to allow 

access to dredge areas of slip. 

• Commence dredging slip below water table by creating opening from 

channel to slip. 

C.) Sequence 3, Duration: 3 months 

• Continue initial dredging of slip. 

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• Mobilize equipment into slip to begin construction in slip. 

• Drive piles for dolphins, trestle, unloading platform for New LNG Berth in 

slip. 

D.) Sequence 4, Duration: 3 months 

• Complete initial dredging of slip. 

• Construct trestle and unloading platform for New LNG Berth in slip. 

• Drive piles for trestle, unloading platform, breasting dolphins, and half of 

the mooring dolphins for New Crude Berth #7 in the slip. 

• Construct trestle for New Crude Berth #7 in slip. 

• Drive piles for tug dock. 

• Begin installation of slope protection on south face of slip. 

E.) Sequence 5, Duration: 2 months 

• Complete unloading platform construction and construct breasting 

dolphins for New LNG Berth in slip. 

• Construct unloading platform for New Crude Berth #7 in slip. 

• Shutdown operations on Existing Berth #7 and remove equipment and 

piping from trestle and platform. 

• Shutdown and remove remaining piping and equipment on Old Existing 

Berth #6. 

• Construct tug dock. 

• Continue installing slope protection on south and east faces of slip. 

F.) Sequence 6, Duration: 2 months 

• Complete breasting dolphin construction and start mooring dolphin 

construction for new LNG Berth in slip. 

• Complete unloading platform construction for New Crude Berth #7 in slip. 

• Demolish Existing Berth #7 marine structures, beginning with southerly 

dolphins and working to the north. 

• Remove temporary sheetpile wall adjacent to Existing Berth #7 and 

Dredge. 

• Drive remaining piles for mooring dolphins for New Crude Berth #7 in slip. 

• Construct breasting dolphins for New Crude Berth #7 in slip. 

• Continue installing slope protection for New Crude Berth #7. 

• Demolish remaining Old Existing Berth #6 marine structures. 

G.) Sequence 7, Duration: 3 months 

• Complete mooring dolphin construction for New LNG Berth in slip. 

• Install piping and equipment on New LNG Berth in slip. 

• Complete construction of New Berth #7 breasting dolphin and construct 

mooring dolphins. 

• Install piping and topside equipment on New Crude Berth #7 in slip. 

• Complete removal of Existing Berth #7 marine structures. 

• Complete removal of remaining slip excavation and dredge material 

within slip area. 

• Continue slope protection installation. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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 Import Terminal Project

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H.) Sequence 8, Duration: 2 months 

• Commission New LNG Berth in slip. 

• Commission New Berth #7. 

• Complete installation of slope protection. 

3.) Vaporization Facilities — Duration: 24 months 

Construction of the Vaporization Facility, which encompasses the core process 

facilities including the IFV’s, BOG compressors, send out pumps, as well as the 

topsides to the marine facilities, pipe racks, auxiliary equipment and the 

controls/administration facilities. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Bayou Casotte Energy LLC Casotte Landing Natural Gas 

 Import Terminal Project

Casotte Landing Natural Gas Draft Storm Water Pollution 

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C.5. SOILS DESCRIPTION 

Site modifications at the LNG Terminal will require surface soils to be disturbed in some 

portions of the site. According to the Soil Survey Geographic Database for Jackson 

County, Mississippi, the proposed Casotte Landing project is dominated by three soil 

series. These include the following: 

• Norfolk fine sandy loam series (north): 2 to 5 percent slopes; it is 

moderately well drained and it has a moderate water capacity. Typical 

soil types associated with Norfolk series includes the Atmore loam, Bayou 

sandy loam, Ocilla loamy sand, Harleston fine sandy loam, and Smithton 

loam. 

• Tidal marsh series (south): contains mucky soils that are generally 

found in association with flat terrain. These soils are drained poorly and 

are often inundated. The tidal marsh series comprises a large proportion 

of the coastline in southeastern Mississippi. It is the underlying stratum 

for much of the local wetlands found near the proposed project area, 

including Grand Bay Swamp. 

• Udorthents (i.e. - dredged deposits): large portions of the Casotte 

Landing project are situated on these soils that have developed as a 

result of either the dredging of Bayou Casotte or the intentional placement 

of dolomite fill within large sections of the proposed terminal location. 

C.6. STORMWATER RUNOFF AND RECEIVING WATERS 

 Stormwater will be carried by surface ditches and swales that run alongside the 

 roads and hurricane levee. The stormwater will then be collected in catch basins 

 located throughout the site. 

 Runoff from the proposed project area will be channeled from the catch basins 

via ditches or sewer pipes (as appropriate) and discharged into Bayou Casotte. 

This is the only receiving water associated with the LNG Terminal. Figure 2, Site 

Storm Drainage Plan, depicts the general drainage patterns during construction. 

This figure was submitted to the Commission on September 30, 2005, as part of 

Volume IV, Figure 1.5.2.1-3.

D. SEDIMENTATION AND EROSION CONTROLS 

Soil erosion and sediment controls are measures that are used to reduce the amount of 

soil particles that may be carried off the work site land area and deposited into receiving 

waterbodies. The purpose of this SWPPP is to identify and discuss the controls that are 

prescribed for the proposed project area to prevent the release of pollutants associated 

with construction activities to waters of the state. The following section details the Best 

Management Practices (BMPs) that will be used for sedimentation and erosion control. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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 Import Terminal Project

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This SWPPP prescribes the following structural and stabilization (i.e. - revegetation) 

BMPs for sedimentation and erosion control, storm water management, and stabilization 

process at the LNG Terminal. 

Structural

• Hay bales; 

• Interceptor dikes; 

• Silt fences; 

• Drainage Swales. 

Stabilization

• Temporary seeding; 

• Permanent seeding; 

• Mulching 

• Vegetative buffer strips; 

• Protection/preservation of trees; 

• Upland revegetation. 

A description of selected standards to be applied during construction, including storm 

water management, erosion control, structural, and stabilization practices, is included 

below. 

D.1. EROSION AND SEDIMENT CONTROLS CRITERIA 

• The construction phase erosion and sediment controls will be designed to 

retain sediment on-site to the extent practical. The controls will include 

but are not limited to silt fences or hay bales, interceptor dikes, trench 

plugs, etc. 

• All control measures will be properly selected, installed, and maintained in 

accordance with manufacturers’ specifications and good engineering 

practices. 

• Daily and weekly inspections will be conducted and if inspections or other 

information indicate a control is being used inappropriately or incorrectly, 

the controls will be replaced or modified for the site situation. 

• If sediment escapes the construction site, off-site accumulations of 

sediment will be removed as frequent as necessary to minimize off-site 

impacts. 

• Controls will be implemented to prevent litter, construction debris, 

equipment fuel and construction materials from being exposed to storm 

water and becoming a pollutant source for storm water discharges (e.g. 

screening outfalls, picking up debris and litter daily and storing chemicals 

inside secondary containment facilities). 

• Bayou Casotte Energy’s Construction Manager, contractors, and 

subcontractors will be responsible for implementation of the applicable 

control measures (outlined above), as well as being responsible for 

monitoring and maintaining these control measures during each phase of 

construction activities. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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 Import Terminal Project

Casotte Landing Natural Gas Draft Storm Water Pollution 

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D.2. STRUCTURAL PRACTICES 

 Structural practices will be used to divert flows from exposed soils, store flows or 

 otherwise limit runoff from exposed areas. Construction work will be completed 

 in consecutive sections to minimize the duration the back-filled material will be 

 exposed, which should ultimately reduce the possibility of erosion problems. The 

 following structural practices include but are not limited to hay bales, interceptor 

 dikes, silt fences, or drainage swales. 

1. Hay bales – During construction activities, hay bales can be used 

 in conjunction with silt fences around spoil piles, near waterbodies, and at 

 locations where erosion hazards are high. Bales must be double staked 

 and imbedded 4 inches into the ground with soil tamped around the bales 

 to secure them in place 

2. Interceptor Dikes - An interceptor dike is a ridge and channel combination 

used to protect work areas from up-slope runoff and to divert sedimentladen water to well-vegetated areas or in the absence of well-vegetated 

areas, silt fences, hay bales or erosion control blankets will be used. The 

dike consists of compacted soil and will be spaced and placed to divert 

water flow onto well-vegetated areas. Temporary interceptor dikes will be 

constructed during initial grading of soil and permanent interceptor dikes 

will be installed as part of the final grading. 

3. Silt Fences- A silt fence, also called a “filter fence,” is a temporary 

measure for sedimentation control. It usually consists of posts with filter 

fabric stretched across the posts and sometimes with a wire support 

fence if conditions require it. The lower edge of the fence is vertically 

trenched and covered by backfill. A silt fence is used in small drainage 

areas to detain sediment. These fences are most effective where there is 

overland flow (runoff that flows over the surface of the ground as a thin, 

even layer) or in minor swales or drainage ways. They prevent sediment 

from entering receiving waters. Silt fences will be placed at the outfall of 

interceptor dikes when native vegetation is insufficient to filter silt from 

runoff water. Silt fences will also be constructed at the base of slopes 

adjacent to roadways, wetlands, and waterbodies. Silt fences will be 

constructed in all cases where a disturbed area is close to a waterbody. 

Silt fences will also be constructed after the preliminary grading in natural 

swales and washes. 

 4. Drainage Swales – Drainage swales are constructed for the purpose of 

managing and containing the flow of excess surface water on the 

construction site. A qualified individual will be responsible for the 

maintenance, operation, and repair of the swales on the site. 

Maintenance, operation and repair shall mean the exercise of practices, 

such as mowing and erosion repair, which allow the swales to provide 

drainage, water storage, conveyance or other stormwater management 

capabilities as permitted by the MDEQ. Filling, excavation, construction 

of fences or otherwise obstructing the surface water flow in the swales will 

be prohibited. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Bayou Casotte Energy LLC Casotte Landing Natural Gas 

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Casotte Landing Natural Gas Draft Storm Water Pollution 

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D.3. STABILIZATION PRACTICES 

 Stabilization practices shall be designed to preserve existing vegetation (where 

 possible) and revegetate disturbed areas as soon as practicable after 

 construction. Stabilization practices that will be employed during construction 

 include but are not limited to: permanent seeding, temporary seeding, mulching, 

 vegetative buffer strips, protection/preservation of natural vegetation, and other 

 appropriate measures. 

 

 Stabilization measures will be initiated as soon as practical in portions of the site 

 where construction activities have temporarily or permanently ceased, but in no 

 case more than 14 days after the construction activity in that portion of the site 

 has temporarily or permanently ceased. 

• Where the initiation of stabilization measures by the 14th day after 

construction activities have temporarily or permanently ceased, is 

precluded by snow cover or frozen ground conditions, stabilization 

measures will be initiated as soon as practical. 

• Where construction activities on a portion of the site has temporarily 

ceased, but earth disturbing activities will be resumed within 21 days, 

temporary stabilization measures will not be initiated for that portion of the 

site. 

• In arid areas (areas with an average annual rainfall of 0 to 10 inches), 

semi-arid areas (areas with average annual rainfall of 10 to 20 inches), 

and areas experiencing droughts where the initiation of stabilization 

measures by the 14th day after construction activities have temporarily or 

permanently ceased is precluded by seasonal arid conditions, 

stabilization measures will be initiated as soon as practical. 

 Revegetation will be performed on all disturbed areas to minimize erosion 

 problems while natural vegetation is restored. If revegetation is required, 

 seeding will most likely be the primary stabilization measure used. Where 

 revegetation is required, it will be implemented on temporary and extraneous 

 work locations (except parking lots and other similar industrial areas) which 

 were disturbed during construction activities. Stabilization measures that 

 could be used to prevent erosion include but are not limited to: 

1. Temporary Seeding - The purpose of temporary seeding is to reduce 

 erosion and sedimentation by stabilizing disturbed areas that will not be 

 stabilized for long periods of time or where permanent plant growth is not 

 necessary or appropriate. Temporary seeding will be used if seasonal 

 weather conditions prevent permanent seeding and mulching from being 

 feasible alternatives. This method utilizes fast-growing grasses whose 

 root systems hold down the soils so that they are less apt to be carried 

 offsite by storm water runoff or wind. Temporary seeding also reduces 

 the problems associated with mud and dust from bare soil surfaces 

 during construction. 

2. Permanent Seeding - For permanent seeding and planting the following 

 steps must be followed: 

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• Seedbed Preparation: it consists on preparing the area for 

 seeding by tilling, use of lime and fertilizers. Seedbed preparation 

 will depend on if the area of preparation is or is not accessible by 

 farm machinery. 

• Seeding: there are two methods commonly used for seeding, a 

 grass drill or a hydroseeder will be used whichever is more 

 practical at the time of the seeding. No seeding by hand is 

 allowed. The seeding mixture and fertilizer must be in accordance 

 with the regional county soil service unless landowner requests 

 otherwise. 

• Mulching: it will be use to aid in plant growth, as mentioned below. 

3. Vegetative Buffer Strips - Buffer zones are vegetated strips of land used 

for temporary or permanent water quality benefits. Buffer zones are used 

to decrease the velocity of storm water runoff, which in turn helps to 

prevent soil erosion. The buffer zone can be an area of vegetation that is 

left undisturbed during construction, or it can be newly planted. 

4. Protection/Preservation of Natural Vegetation – Protection and 

preservation of vegetation on a site should be planned before any site 

disturbance begins. It requires good site management to minimize the 

impact of construction activities on existing vegetation. Clearly mark the 

trees to be preserved and protect them from ground disturbances around 

the base of the tree. Proper maintenance is important to ensure healthy 

vegetation that can control erosion. Different species, soil types, and 

climatic conditions will require different maintenance activities such as 

mowing, fertilizing, liming, irrigation, pruning, and weed and pest control. 

5. Mulching - Mulching is a temporary soil stabilization or erosion control 

practice where materials such as hay, woodchips, wood fibers, or straw 

are placed on the soil surface. In addition to stabilizing soils, mulching 

can reduce the speed of storm water runoff over an area. When 

used together with seeding or planting, mulching can aid in plant 

growth by holding the seeds, fertilizers, and topsoil in place, by helping to 

retain moisture, and by insulating against extreme temperatures. 

Hydroseeding and hydromulching may be a feasible alternative to be 

considered. 

6. Upland Revegetation- the purpose of this practice is to provide perennial 

vegetative cover in order to prevent soil erosion and control 

sedimentation. Vegetation shall be used as temporary and/or permanent 

erosion control measure. The combination of one or more of the following 

controls may be required or needed. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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E. OTHER POLLUTION CONTROLS 

E.1. CHEMICAL STORAGE AREA 

 Materials will be stored and properly contained in a Chemical Storage Area, as 

applicable. A list of chemicals that could be reasonably expected to be brought 

or stored on site include, but are not limited to the following: 

- Paints 

- Cleaning Solvents 

- Fiberglass Resin 

 - Fusion Bon Epoxy 

 - Sack Crete 

 - Sandblasting Material 

 - Coal Tar Epoxy 

 

• On-site storage of construction materials or hazardous chemicals will be 

minimized to the extent possible. On-site storage will be staged and 

mobile according to the section of pipeline presuming active construction. 

• Tarps and other materials used for covering, drip pans and secondary 

containment structures other materials will be used for covering as 

necessary. 

• All materials and chemicals brought on-site will be stored in their original 

containers with original manufacturer’s labels and managed with good 

housekeeping practices. 

• All containers of materials or chemicals must be maintained in good 

condition and kept in an upright position with lids closed except when 

materials are being removed for use. 

• Mixing substances will not be allowed except when following 

manufacturer’s recommendations. 

• Containers will be disposed of only when they are considered “empty”. 

• Manufacturer’s recommendations for proper use and disposal of materials 

or chemicals must be followed. 

• The Contractor’s Project Manager or Bayou Casotte Energy’s 

Construction Manager will be responsible to perform routine inspections 

to ensure materials and chemicals are being used, stored and disposed 

of properly. 

• It is also the responsibility of the Construction Manager to ensure that 

Material Safety Data Sheets are on-site and made readily accessible to 

all associates who will be exposed to chemicals. 

• Disposal of surplus materials or chemicals must be performed according 

to manufacturer’s recommendation and local, state and federal 

regulations. 

• It will be the responsibility of the paint contractor to remove and properly 

dispose of all paint waste (i.e. empty paint and solvent containers, etc.). 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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E.2. FUELING AND MAINTENANCE AREA 

Materials will be stored and properly contained within the Fueling and 

Maintenance Area, as applicable. Materials that could be reasonably 

expected to be brought or stored on site include, but are not limited to: 

– Motor oils; 

– transmission and brake fluids; 

– hydraulic fluids; 

– lubricating fluids; 

– antifreeze; and 

– portable fuel containers. 

• All vehicles brought or maintained on-site will be on a regular preventative 

maintenance inspection schedule to reduce the risk for fuel and oil spills. 

• Drip pans must be used during vehicle fueling activities at the 

construction site to minimize the risk of tank overfills that could result in 

fuel spills. 

• Off-site vehicle tracking of sediments and generation of dust will be 

minimized. 

E.3 WASTE STORAGE AREA 

 Materials will be stored and properly contained in a Waste Storage Area, as 

applicable. A list of products that could be reasonably expected to be brought or 

stored on site include, but are not limited to the following: 

- Diesel 

- Gasoline 

- Hydraulic Oil 

- Lube Oil 

- Equipment Grease 

• Generation of waste will be minimized to the extent possible. All wastes 

generated during construction activities will be managed in accordance 

with applicable laws and regulations. Construction waste will not be 

burned or buried on site. 

• Any hazardous waste that is generated during construction will be 

managed according to local, state and federal regulations. 

• Portable sanitary waste units will be made available at all construction 

sites. All sanitary waste from the portable units will be managed by a 

licensed sanitary waste management company, as required by the local 

government agencies. 

F. APPROVED STATE, TRIBAL OR LOCAL PLANS 

Not Applicable 

G. MAINTENANCE 

All erosion and sediment control measures and other protective measures identified in 

the SWPPP will be maintained in effective operating condition. If site inspections as 

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outlined below reveal that these control measures are operating ineffectively, 

maintenance will be performed before the next anticipated storm event, or as necessary 

to maintain the continued effectiveness of storm water controls. If maintenance prior to 

the next anticipated storm event is impracticable, maintenance will be scheduled and 

accomplished as soon as practical. 

H. INSPECTIONS 

Qualified personnel (provided by Bayou Casotte Energy or its contractors/ 

subcontractors will inspect the construction site as follows: 

• Daily - Inspecting equipment fueling areas, construction materials, litter 

control, etc. 

• General Site Control BMP Checklist (conducted at least once every 

Seven (7) calendar days for a minimum of four inspections per month); 

• As often as necessary to ensure that appropriate erosion and sediment 

controls have been properly constructed and maintained and determine if 

additional or alternative control measures are required. It is strongly 

recommended by the MDEQ that coverage recipients perform a “walk 

through” inspection of the construction site before anticipated storm 

events. 

Inspections must be performed as specified below to ensure that erosion and sediment 

controls measures are maintained and functioning as designed. 

H.1. CONSTRUCTION INSPECTION RESPONSIBILITIES 

Bayou Casotte Energy will be responsible for routinely inspecting erosion control 

measures as specified below; or within 24 hours of the end of a storm event. These 

inspections are performed to ensure that control measures are in proper working 

condition. All inspection forms are located within Attachment 2. 

Inspection Form / Litter Control; 

Complete Daily Inspection / Litter Control Checklist, to ensure BMPs are effective in 

preventing stormwater pollution and maintaining good housekeeping practices. 

General Site / Post Storm Erosion Control; 

Complete General Site Control / Post-Storm Checklist, to ensure all erosion control 

measures are inspected at least once every seven (7) days or subsequent to a 

significant storm event with 0.5 inches or greater rainfall. All control measures must be 

maintained in proper working condition and repaired as necessary. As presented in the 

checklist, the following will be reviewed during these inspections: 

• Construction entrances will be inspected where vehicles enter or exit the site for 

evidence of off-site sediment tracking. 

• All material storage areas exposed to precipitation will be inspected for evidence of 

or the potential for pollutants entering the storm drain system. 

• Inspect storm water discharge locations or other accessible points to ascertain 

whether erosion control measures are effective in preventing significant impacts to 

receiving waters. Where discharge locations are inaccessible, nearby downstream 

locations shall be inspected to the extent that such inspections are practicable. 

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• Inspect discharge locations for sediment or other pollutants that may have been 

discharged from the site. 

• Identify the location of the BMPs that need to be maintained; or that potentially failed 

to operate as designed or proved inadequate for a particular location; and/or 

locations where additional BMPs might be needed that did not exist at the time of the 

inspection. 

Prepare and submit inspection reports to Bayou Casotte Energy’s Construction Manager 

at the completion of the inspection. Based on the results of the inspections, the SWPPP 

shall be modified as necessary to include additional or modified BMPs designed to 

correct problems identified. Revisions to the SWPPP shall be completed within 7 

calendar days following the inspection. Records will be maintained in the Construction 

Manager's office (or trailer). 

If existing BMPs need to be modified or if additional BMPs are necessary, 

implementation will be completed before the next anticipated storm event. If 

implementation before the next anticipated storm event is impracticable, they will be 

implemented as soon as practicable. 

H.2. POST CONSTRUCTION INSPECTION RESPONSIBILITIES 

After the construction project has been completed, Bayou Casotte Energy will inspect 

the project site monthly for vegetation re-establishment, until the revegetation has 

achieved 70% of its native coverage. A Bayou Casotte Energy Post Construction Form 

must be completed by Bayou Casotte Energy’s Construction Manager during each 

inspection. The form is located within Attachment 2 of this SWPPP. 

H.3. INSPECTION DOCUMENTATION 

The inspections described in Section H must be documented on copies of the MDEQ 

Monthly Inspection Report and Certification Form. The form is located within Attachment 

2 of this SWPPP. The forms shall be retained within this SWPPP for at least three years 

from the date of construction. 

H.4. RETENTION OF RECORDS 

Copies of this SWPPP and all documentation required by the NPDES construction 

general permit must be retained for at least three (3) years from the date that the NOT is 

submitted to the MDEQ. This period may be extended by request of MDEQ at any time. 

The following records must be retained: 

• A copy of this SWPPP; 

• All reports and actions required by the general permit, including a copy of the 

 construction site notice; and 

• All data required to complete the Notice of Intent for coverage under the 

 general permit. Once site modifications are complete, the site will become 

 an operational LNG facility and NOIs will be filed for coverage of the site under 

 the NPDES Multi-Sector General Permit for Stormwater Discharge Associated 

 With Industrial Facilities and the NPDES General Permit for Concrete 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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 Production Facilities. A separate SWPPP will be implemented to meet 

 requirements of these permits. 

I. NON-STORM WATER DISCHARGES 

Non-storm water discharges will be minimal at the LNG Terminal. However, 

uncontaminated water will be used at various intervals to aid in dust suppression at the 

facility. Other potential sources may include uncontaminated wash down, line flushing 

water and irrigation runoff. 

I.1. HYDROSTATIC TESTING 

 The LNG inner container will be hydrotested in accordance with API 620. The 

 hydrotest water will be supplied only from an acceptable source, such as treated 

 wastewater from the Refinery, or appropriately treated water from the Bayou 

 Casotte. The necessary permits prior to withdrawal and discharge of water for 

 hydrostatic testing will be obtained. Hydrostatic test water will be pumped into 

 the tank at rates not exceeding the limitation set forth by API 620 and piped into 

 the inner container through the manhole in the outer container concrete roof. 

 

 1. Residence time in the tank will be limited to approximately seven weeks 

 from start of filling to completion of emptying. 

 2. Approximately 28 million gallons of water will be required to test up to the 

 required test level. It is envisioned that test water will be transferred 

 among tanks and ultimately discharged into the Bayou Casotte Channel. 

 3. Test water will be sampled and tested for suitability prior to use, in 

 accordance with MDEQ requirements, procedures, and approvals. Prior 

 to discharge, the water will be tested again, in accordance with MDEQ 

 requirements, procedures, and approvals to determine whether treatment 

 is required and to establish an appropriate treatment method. 

 4. Specific procedures will be developed for treating water prior to discharge 

 (filtration, oil/water separators, clarifiers, activated carbon adsorption 

 units, chemical injection, etc.) 

J. PROPER OPERATIONS AND MAINTENANCE 

Bayou Casotte Energy will at all times properly operate and maintain all facilities and 

treatment systems as well as control and related appurtenances which are installed or 

used to achieve compliance with the conditions of the permit and the requirements of 

storm water pollution prevention plans. 

K. SPILL PREVENTION 

Each Bayou Casotte Energy employee and contractor must maintain good 

housekeeping practices and take precautionary measures as appropriate to prevent 

spills. In addition, proper material management practices will be employed to reduce the 

risk of spills or other accidental exposure of construction materials or substances to 

stormwater runoff. 

Should a spill occur, Bayou Casotte Energy on-site personnel must be notified 

immediately. Spills must be contained and cleared up as quickly as possible. In 

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addition, Bayou Casotte Energy will implement the Emergency Response Plan (ERP) 

that will be readily available at the facility. 

K.1. GOOD HOUSEKEEPING 

 The following good housekeeping practices will be followed on site during the 

 construction phase of this project: 

• Store only enough materials on site as required to perform the job; 

• All materials stored on site will be stored in a neat and orderly manner in 

appropriate containers, and protected from damage; 

• All materials on site will be kept in their original containers with the 

original manufacturer’s labels wherever possible. Materials transferred to 

other containers will be properly labeled; 

• Containers on site will be completely emptied and lids removed before 

disposal; 

• Chemicals or containers will not be burned or buried at the project site; 

• Manufacturer’s recommendations for proper use and disposal of the 

materials or substances and disposal of containers will be followed; and 

• The site operator, or a qualified and responsible representative, will 

ensure proper use and disposal of construction materials or substances. 

K.2 HAZARDOUS PRODUCTS 

 The following practices will be used to minimize the risks associated with 

 hazardous products during the construction phase of this project: 

• Hazardous products will be kept in their original containers unless the 

containers are not resealable; 

• Original labels and Material Safety Data Sheets (MSDS) will be 

maintained on site; 

• If surplus materials must be disposed of, the manufacturer’s disposal 

recommendations will be used in coordination with federal, state, and 

local requirements regarding proper disposal. Waste material will not be 

poured into waterways, drains, septic tanks, or onto the ground. 

Materials will be recycled, reused, or returned to the manufacturer 

whenever possible. 

K.3 PRODUCT SPECIFIC PRACTICES 

 Product specific practices to be used during the course of this project include: 

• Petroleum Products – On site vehicles, vessels, equipment, and 

machinery will be monitored for leaks and will receive regular preventative 

maintenance to reduce the possibility of leakage. Petroleum products will 

be stored in tightly sealed containers which are clearly labeled and 

protected from damage. All petroleum-based substances used on site 

will be used in accordance with manufacturer’s recommendations. 

 Refueling and lubricating of construction equipment shall be restricted to 

 upland areas at least 100 feet from the edge of any streams, 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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 wetlands, ditches, and other waterbodies; 200 feet from private water 

 supply wells; and 400 feet from public water supply wells, wherever 

 possible. 

• Paints and Solvents - All containers will be tightly sealed and stored 

when not in use. Surplus paint and solvent, as well as other similar 

materials, will be disposed of in accordance with manufacturer’s 

recommendations and federal, state, and local requirements. 

L. TRAINING 

Any employee working at the project site has the potential to cause pollution of the 

stormwater. Therefore, all employees must receive annual training on this SWPPP. The 

dates and attendees must be documented per each training class. Copies of the training 

documentation will be maintained by Bayou Casotte Energy. 

It shall be the responsibility of Bayou Casotte Energy, its Contractors and their 

employees to read, understand and comply with the requirements and commitments set 

forth in this Storm Water Pollution Prevention Plan. 

M. TERMINATION OF PERMIT COVERAGE 

Permittees wishing to terminate coverage under the NPDES general permit must submit 

the applicable Notice of Termination (NOT) to the MDEQ. Compliance with the permit is 

required until a NOT is submitted. 

Per the MDEQ Permit No.MSR10, within 30 days of final stabilization (see Definition of 

Final Stabilization (1)) for a covered project, a completed Notice of Termination (NOT) of 

Coverage form shall be submitted to the Permit Board. Upon receiving the completed 

NOT, the MDEQ staff will inspect the site. If no sediment and erosion control problems 

are identified and adequate permanent controls are established the owner and operator 

will receive a termination letter. Coverage is not terminated until done so in writing. 

Failing to submit a NOT is a violation of permit conditions. 

The coverage recipient must submit a NOT within 30 days after the following conditions 

are met: 

• Final stabilization (see Definition of Final Stabilization (2)) has been 

achieved on all portions of the site for which the coverage recipient is 

responsible. 

• Other owner(s) or operator(s) have assumed control (by completing a 

CNOI or MDEQ Registration Form) over all areas of the site that have 

not achieved final stabilization. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Bayou Casotte Energy LLC Casotte Landing Natural Gas 

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Casotte Landing Natural Gas Draft Storm Water Pollution 

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ATTACHMENT 1 

Proposed Route Site Maps 

The attached site maps will indicate the following: • Location of receiving waters closest to project site. 

• Location of roadway, railroad, waterbody, and wetland crossings. 

• Major structural controls are not anticipated to be used for this project. 

• Non-structural controls will consist of items discussed in Section D of this SWPPP. 

Given the mobile nature of these non-structural controls, they have not been 

included in the SWPPP site maps for this project. 

• Stabilization practices are expected to occur on an as-needed basis along the length 

of the pipeline and therefore specific locations are not identified. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Bayou Casotte Energy LLC Casotte Landing Natural Gas 

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Casotte Landing Natural Gas Draft Storm Water Pollution 

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ATTACHMENT 2 

NOTICE OF INTENT 

And 

NPDES PERMIT 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Bayou Casotte Energy LLC Casotte Landing Natural Gas 

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- Casotte Landing Natural Gas Draft Storm Water Pollution 

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ATTACHMENT 3 

Inspection Forms 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ATTACHMENT 3 

STORM WATER POLLUTION PREVENTION PLAN 

BEST MANAGEMENT PRACTICES 

DAILY INSPECTION FORM / LITTER CONTROL CHECKLIST 

Date: Time: 

Performed By: 

Maintenance Supervisor Approval: 

Casotte Landing Natural Gas Draft Storm Water Pollution 

 Import Terminal Project Prevention Plan

To be performed daily. 

Project Location : 

Yes No Activity Initials 

 Are controls being implemented to prevent litter from being exposed to storm water 

and becoming a pollutant source for storm water discharge? 

 Are controls being implemented to prevent construction debris from being exposed 

to storm water and becoming a pollutant source for storm water discharge? 

 Are controls being implemented to prevent equipment fuel from being exposed to 

storm water and becoming a pollutant source for storm water discharge? 

 Are controls being implemented to prevent construction chemicals from being 

exposed to storm water and becoming a pollutant source for storm water discharge? 

 Are on-site storage of construction materials or hazardous chemicals being minimized 

to the extent possible? 

 Are tarps and other materials used for covering as necessary, i.e., drip pans and 

secondary containment structures? 

 Are all materials and chemicals brought on-site stored in their original containers? 

 Are all containers of materials or chemicals maintained in good condition and kept in 

an upright position with lids closed except when materials are being removed for use? 

 Is the mixing of substances only occurring per manufacturer’s recommendations? 

 Are material and chemical containers disposed of properly when they are considered 

“empty”? 

 Are manufacturer’s recommendations for proper use and disposal of materials or 

chemicals being followed? 

 Are materials and chemicals being used, stored and disposed of properly? 

 Are MSDS’s on-site and made readily accessible to all associates who will be exposed 

to chemicals? 

 Are disposal of surplus materials or chemicals being performed according to 

manufacturer’s recommendation and local, state and federal regulations? 

 Did the paint contractor remove and properly dispose of all empty paint and solvent 

cans generated during construction? 

 Are all vehicles brought or maintained on-site on a regular preventative maintenance 

inspection schedule to reduce the risk for fuel and oil spills? 

 Are drip pans used during vehicle fueling activities at the construction site to minimize 

the risk of tank overfills that could result in fuel spills? 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ATTACHMENT 3 

STORM WATER POLLUTION PREVENTION PLAN 

BEST MANAGEMENT PRACTICES 

DAILY INSPECTION FORM / LITTER CONTROL CHECKLIST 

Date: Time: 

Performed By: 

Maintenance Supervisor Approval: 

Casotte Landing Natural Gas Draft Storm Water Pollution 

 Import Terminal Project Prevention Plan

 Is the off-site vehicle tracking of sediments and generation of dust being minimized? 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ATTACHMENT 3 

STORM WATER POLLUTION PREVENTION PLAN 

BEST MANAGEMENT PRACTICES 

GENERAL SITE CONTROL / POST-STORM CHECKLIST 

Date: Time: 

Performed By: 

Maintenance Supervisor Approval: 

Casotte Landing Natural Gas Draft Storm Water Pollution 

 Import Terminal Project Prevention Plan

All erosion control measures must be inspected at least once every fourteen (14) 

calendar days and subsequent (within 24 hours) to any storm event with 0.5 inches or 

greater rainfall. 

Project Location: 

Date 

Completed Initials Activity 

 

Inspect the completed sections along the pipeline right-of-way for erosion 

problems (i.e. bare spots and washouts). 

 

Inspect construction entrances where vehicles enter or exit the site for 

evidence of off-site sediment tracking. 

 

Inspect all material storage areas exposed to precipitation for evidence of 

or the potential for, pollutants entering the storm drain system. 

 

Inspect storm water discharge locations or points where accessible to 

ascertain whether erosion control measures are effective in preventing 

significant impacts to receiving waters. 

 

Inspect discharge locations for sediment or other pollutants that may have 

been discharged from the site. 

 

Identify location of the Best Management Practices (BMPs) that need to 

be maintained; or that potentially failed to operate as designed or proved 

inadequate for a particular location; and/or locations where additional 

BMPs might be needed that did not exist at the time of the inspection. 

Are changes to the SWPPP warranted?  Yes  No 

If yes, please notify the Project Engineer and the OID Contact. 

Remarks: 

 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ATTACHMENT 3 

STORM WATER POLLUTION PREVENTION PLAN 

BEST MANAGEMENT PRACTICES 

GENERAL SITE CONTROL / POST-STORM CHECKLIST 

Date: Time: 

Performed By: 

Maintenance Supervisor Approval: 

Casotte Landing Natural Gas Draft Storm Water Pollution 

 Import Terminal Project Prevention Plan

Please make sure all problems identified are corrected before next anticipated storm event or 

inspection, which ever is sooner.

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Bayou Casotte Energy LLC Casotte Landing Natural Gas 

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Casotte Landing Natural Gas Draft Storm Water Pollution 

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UPON FINALIZATION, INSERT MDEQ INSPECTION AND CERTIFICATION FORM HERE 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Bayou Casotte Energy LLC Casotte Landing Natural Gas 

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Casotte Landing Natural Gas Draft Storm Water Pollution 

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UPON FINALIZATION, INSERT MDEQ INSPECTION SUSPENSION FORM HERE 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Bayou Casotte Energy LLC Casotte Landing Natural Gas 

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Casotte Landing Natural Gas Draft Storm Water Pollution 

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ATTACHMENT 3 

STORM WATER POLLUTION PREVENTION PLAN 

BAYOU CASOTTE ENERGY POST CONSTRUCTION INSPECTION REPORT 

STABILIZATION MONITORING 

PROJECT 

LOCATION 

DATE 

PROJECT 

COMPLETED 

DATED 

LOCATION 

DRESSED 

IS THERE 

SIGNS OF 

EROSION? 

WAS A DISCHARGE OF 

POLLUTANTS/SEDIMENT 

OBSERVED? 

Yes or No? 

PERCENT 

STABILIZED 

COMMENTS 

 

Please note: If signs of erosion are noted, utilize stabilization practices and 

erosion control methods defined in the SWPPP. If a pollutant discharge is 

observed, further discharge should be prevented to the extent possible and 

BAYOU CASOTTE ENERGY’s Project Manager needs to notified as soon as 

possible. 

Once Final Stabilization (70% revegetation) is achieved, no further inspection is 

necessary. Notify BAYOU CASOTTE ENERGY’s Construction Project Manager 

or Field Operations when Final Stabilization has been achieved. 

Date: Contractor’s Name: 

Maintenance required for: (Specify by 

location or mile post number). 

Maintenance to be performed by on or before 

 .

Are changes to the SWPPP warranted? 

If so, note the required revisions and reasons for changes. 

________________________________________________________________________________ 

________________________________________________________________________________ 

________________________________________________________________________________ 

________________________________________________________________________________ 

________________________________________________________________________________ 

________________________________________________________________________________ 

________________________________________________________________________________ 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX D 

SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN 

FOR CONSTRUCTION ACTIVITIES 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SPILL PREVENTION CONTROL AND 

COUNTERMEASURE (SPCC) PLAN FOR 

CONSTRUCTION ACTIVITIES 

FOR 

BAYOU CASOTTE ENERGY LLC 

CASOTTE LANDING NATURAL GAS 

IMPORT TERMINAL 

PASCAGOULA, MISSISSIPPI 

Bayou Casotte Energy LLC 

Casotte Landing Natural Gas Import Terminal 

Address To Be Established 

Pascagoula, Mississippi, 39567 

January 2006 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

SPILL PREVENTION CONTROL AND 

COUNTERMEASURE (SPCC) PLAN FOR 

CONSTRUCTION ACTIVITIES 

- DRAFT - 

Facility Name: Casotte Landing Natural Gas Import Terminal 

Address: Address To Be Established

Pascagoula, Mississippi, 39567 

Phone Number 

(24 hours/day): To Be Established

Latitude: 30 degrees 20 minutes 04 seconds 

Longitude: 88 degrees 29 minutes 37 seconds 

Owner: Bayou Casotte Energy LLC 

Contact Person: Michael J. DeNicola (832) 854-6228 

Revision Date: January 2006 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

List of Acronyms 

CFR Code of Federal Regulations 

DOT Department of Transportation 

EPA Environmental Protection Agency 

ERP Emergency Response Plan 

FERC Federal Energy Reserve Commission 

FSO Facility Security Officer 

LNG Liquefied Natural Gas 

MDEQ Mississippi Department of Environmental Quality 

N/A Not Applicable 

NPDES National Pollutant Discharge Elimination System 

NRC National Response Center 

P.E. Professional Engineer 

SPCC Spill Prevention, Control, and Countermeasures Plan 

USCG United States Coast Guard 

USTs Underground Storage Tanks 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Log of Plan Review and Amendments 

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

The SPCC must be prepared and implemented prior to the commencement of site activity. 

Therefore, upon determination of the construction contractor, this SPCC will be finalized 

and certified prior to the commencement of construction activities. 

As required by 40 CFR 112.5(a), the Plan will be amended when there is a change to the 

facility design, construction, operation or maintenance that materially affects its potential for 

a discharge as described in 40 CFR 112.1(b). Any technical amendment will be certified by 

a Professional Engineer (P.E.) in accordance with 40 CFR 112.5(c). An amendment made 

under this section will be prepared within six (6) months of the change and implemented as 

soon as possible but not later than six (6) months following preparation of the amendment. 

Technical amendments affecting various pages within the plan can be P.E. certified on those 

pages, certifying those amendments only, and will be documented on the following log form. 

Non-technical amendments are not certified by a P.E. Examples of non-technical 

amendments include, but are not limited to, phone numbers, name changes, or any nontechnical text change(s). Management will review this SPCC plan at least every five (5) 

years and document the review on the log form. 

A complete copy of the SPCC Plan will be maintained by Bayou Casotte Energy personnel 

and will be available for review during normal working hours [40 CFR 112.3(e)(1)]. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Log of Plan Review and Amendments 

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

LOG OF PLAN REVIEW AND AMENDMENTS 

Review/ 

Amend 

Date 

Signature 

Amend Plan 

(will/will 

not) 

Description of Review 

Amendment 

Affected 

page(s) 

P.E. 

Cert.? 

(Y/N) 

 

 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
TABLE OF CONTENTS

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

ONSHORE FACILITY - REGULATORY CROSS-REFERENCE

Citation Description Section

§112.3(d)(1) Professional Engineer Certification 2.2 

§112.5(b) Management of Five Year Review 2.1 

§112.7 General requirements for SPCC Plans for all facilities and all oil types -- 

§112.7(a) General requirements: discussion of facility’s conformance with rule requirements; deviations from Plan 

requirements; facility characteristics that must be described in the Plan; spill reporting information in the Plan; 

emergency procedures 

Section 2, 

Figures 1 

and 2, 3.2, 

3.2.4 

§112.7(b) Fault analysis 3.2.3 

§112.7(c) Secondary containment 3.3, 

3.3.13.3.2, 

3.3.3 

§112.7(d) Contingency planning -- 

§112.7(e) Inspections, tests, and records 3.4 

§112.7(f) Employee training and discharge prevention procedures 3.5 

§112.7(g) Security (excluding oil production facilities) 3.6 

§112.7(h) Loading/unloading (excluding offshore facilities) 3.7 

§112.7(i) Brittle fracture evaluation requirements 4.2.1 

§112.7(j) Conformance with State requirements 3.8 

§112.8(a) General and specific requirements for onshore facilities (excluding production facilities) Section 4 

§112.8(b) Facility drainage 4.1 

§112.8(c) Bulk storage containers 4.2 

§112.8(d) Facility transfer operations, pumping, and facility process 4.3 

§112.9 Requirements for onshore production facilities N/A 

§112.9(a) General and specific requirements N/A 

§112.9(b) Oil production facility drainage N/A 

§112.9(c) Oil production facility bulk storage containers N/A 

§112.9(d) Facility transfer operations, oil production facility N/A 

§112.10) Requirements for onshore oil drilling and workover facilities N/A 

§112.10(a) General and specific requirements N/A 

§112.10(b) Mobile facilities N/A 

§112.10(c) Secondary containment - catchment basins or diversion structures N/A 

§112.10(d) Blowout prevention (BOP) N/A 

§112.11 Requirements for offshore oil drilling, production, or workover facilities N/A 

§112.11(a) General and specific procedures N/A 

§112.11(b) Facility drainage N/A 

§112.11(c) Sump systems N/A 

§112.11(d) Discharge prevention systems for separators and treaters N/A 

§112.11(e) Atmospheric storage or surge containers; alarms N/A 

§112.11(f) Pressure containers; alarm systems N/A 

§112.11(g) Corrosion protection N/A 

§112.11(h) Pollution prevention system procedures N/A 

§112.11(i) Pollution prevention systems; testing and inspection N/A 

§112.1(j) Surface and subsurface well shut-in valves and devices N/A 

§112.11(k) Blowout prevention N/A 

§112.11(l) Manifolds N/A 

§112.11(m) Flowlines, pressure sensing devices N/A 

§112.11(n) Piping; corrosion protection N/A 

§112.11(o) Sub-marine piping; environmental stresses N/A 

§112.11(p) Inspections of sub-marine piping N/A 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
TABLE OF CONTENTS

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

1.1 Regulatory background..........................................................................1 

1.2 SPCC PLAN COMPONENTS ..............................................................1 

2.1 Management Commitment [40 CFR 112.3(e)]......................................1 

2.2 Professional Engineer Certification [40 CFR 112.3(d)] .....................2 

2.3 Substantial Harm Criteria and Flowchart [40 CFR 112.20] ................3 

2.4 AMENDMENT OF SPCC plan by regional administrator 

[40 cfr 112.4] .........................................................................................5 

2.5 notification of state agency [40 cfr 112.4(c)] ..........................................5 

2.6 NOTIFICATION OF FEDERAL AGENCY...........................................6 

2.7 amendment of spcc plan by owner or operator [40 cfr 112.5] .............6 

2.7.1 Plan Review [40 CFR 112.5(b)] ...............................................7 

2.7.2 Re-Certification [40 CFR 112.5(c)]..........................................7 

3.1 General facility description [40 cfr 112.7(a)(3)] ...................................1 

3.2 emergency response Information[40 cfr 112.7(a)(5)]............................2 

3.2.1 Written Commitment of Resources ...........................................2 

3.2.2 Spill Response Procedures and Corrective Measures................2 

3.2.3 Prediction of Direction, Rate of Flow, and Quantity of 

Discharge [40 CFR 112.7(b)] .................................................3 

3.2.4 Emergency Telephone Numbers................................................3 

3.3 Description of containment and diversionary structures [40 cfr 

112.7(c)].................................................................................................4 

3.3.1 Secondary Containment.............................................................5 

3.4 Inspections, Tests, and Records [40 CFR 112.7(e)] .............................5 

3.5 Personnel, training, and discharge prevention procedures [40 

cfr 112.7(f)]............................................................................................5 

3.6 SEcurity [40 cfr 112.7(g)]......................................................................6 

3.7 facility tank car and tank unloading/loading rack (excludes 

offshore facilities) [40 cfr 112.7(h)] ......................................................7 

3.8 Conformance With Other Applicable Guidelines [40 CFR 

112.7(j)] .................................................................................................7 

4.1 Facility Drainage [40 CFR 112.8(b)].....................................................1 

4.2 Bulk Storage Tanks [40 CFR 112.8(c)] .................................................1 

4.2.1 Brittle fracture evaluation requirements [40 CFR 

112.7(i)] 2 

4.3 facility transfer operations, pumping, and facility process [40 

cfr 112.8(d)] ...........................................................................................2 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
TABLE OF CONTENTS

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

TABLES 

TO BE ADDED PRIOR TO COMMENCEMENT OF CONSTRUCTION 

ACTIVITIES 

Table 1 Storage Unit Inventory 

Table 2 Secondary Containment Structures 

FIGURES 

TO BE ADDED PRIOR TO COMMENCEMENT OF CONSTRUCTION 

ACTIVITIES 

Figure 1 Site Location Map 

Figure 2 Site Drainage Map 

APPENDICES 

TO BE ADDED PRIOR TO COMMENCEMENT OF CONSTRUCTION 

ACTIVITIES 

Appendix A Secondary Containment Calculations 

Appendix B Inspection Forms 

Appendix C Spill Response Equipment Inventory 

Appendix D Spill History Log 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION ONE GENERAL INFORMATION 

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

1-1

1.1 REGULATORY BACKGROUND 

The Federal Water Pollution Control Act amendments of 1972 require the Administrator of 

the Environmental Protection Agency (EPA), with other federal, state and regional agencies, 

to establish programs designed to prevent or reduce pollution of the waters of the United 

States. The EPA published regulations to prevent pollution of waters of the United States by 

oil emanating from non-transportation related facilities at 40 CFR 112 on December 11, 

1973. This Spill Prevention Control and Countermeasure Plan (SPCC) is prepared in 

accordance with the requirements of Federal regulations 40 CFR 112.7. 

The regulations require the preparation and implementation of an SPCC Plan for all nontransportation related facilities which could reasonably be expected to discharge oil into the 

navigable water of the United States or adjoining shorelines. The Bayou Casotte Energy, 

LLC, Casotte Landing Natural Gas Import Terminal is an onshore liquefied natural gas 

(LNG) import terminal and is therefore subject to the requirement of 40 CFR Part 112 to 

prepare and implement a SPCC Plan. The facility, due to its location could reasonably be 

expected to discharge LNG, oil, and/or similar petrochemical products into navigable waters 

of the U.S. or adjoining shoreline (40 CFR 112.1(b)). 

1.2 SPCC PLAN COMPONENTS 

The objective of this Construction SPCC Plan is to provide preventative measures to be 

employed during construction of the Casotte Landing Terminal. The measures are 

established to minimize the occurrence of an event that results in spills or releases of fuel, 

lubricants, or other materials at storage areas, during normal construction and fueling 

activities. General Information

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION TWO GENERAL REQUIREMENTS

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

2-1

2.1 MANAGEMENT COMMITMENT [40 CFR 112.3(E)] 

Company: Bayou Casotte Energy LLC 

Location: Pascagoula, Jackson County, Mississippi 

Person of Authority: To Be Established

 

I am authorized to commit the necessary resources to carry out the Spill Prevention Control 

and Countermeasures (SPCC) Plan. These necessary resources may include the time and 

efforts of in-house personnel, the time and effort of professional contractors, the allocation of 

existing equipment, the use of rental equipment, and/or the allocation of monies required to 

modify existing facilities as required by this SPCC Plan. Bayou Casotte Energy LLC is 

committed to the operation of its facilities in a manner that promotes the preservation and 

protection of the environment and which protects the health, safety and well being of its 

employees, neighbors, and the general public.

 Signed: _________________________________ 

 To Be Established

 Date Signed: ____________________________ 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION TWO GENERAL REQUIREMENTS

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

2-2

2.2 PROFESSIONAL ENGINEER CERTIFICATION [40 CFR 

 112.3(D)] 

Professional Engineer certification will be completed prior to Plan certification with 

the designated construction contractor. 

I hereby certify that I have personally examined the facility and being familiar with 

the regulations of 40 CFR Part 112 attests that this SPCC Plan has been prepared in 

accordance with good engineering practices including consideration of applicable 

industry standards. I have verified that the required inspection and testing procedures 

have been established as set forth in the Plan. I have verified that the Plan is adequate 

for the Facility. 

Name: 

Signature: 

State: Mississippi 

Registration Number: 

Seal: 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION TWO GENERAL REQUIREMENTS

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

2-3

2.3 SUBSTANTIAL HARM CRITERIA AND FLOWCHART [40 CFR 

 112.20] 

FACILITY NAME: Casotte Landing Natural Gas Import Terminal

FACILITY ADDRESS: To Be Established, Pascagoula, MS 39567

1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater 

than or equal to 42,000 gallons? 

 XX YES NO 

2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack 

secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus 

sufficient freeboard to allow for precipitation within any aboveground oil storage tank area? 

 YES XX NO 

3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a 

distance (as calculated using the appropriate formula in Attachment C-III to this appendix or a comparable formula) such 

that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description 

of fish and wildlife and sensitive environments, see Appendices I, II, and III to DOC/NOAA’s “Guidance for Facility and 

Vessel Response Plans: Fish and Wildlife and Sensitive Environments” (59 FR 14713, March 29, 1994) and the applicable 

Area Contingency Plan. 

 XX YES NO 

4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a 

distance (as calculated using the appropriate formula in Attachment C-III to this appendix or a comparable formula) such 

that a discharge from the facility would shut down a public drinking water intake? 

 YES XX NO 

5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility 

experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last 5 years? 

 YES XX NO 

CERTIFICATION 

I certify under penalty of law that I have personally examined and am familiar with the information submitted in this 

document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the 

submitted information is true, accurate, and complete. 

Signature Title . 

Name Date .

(please type or print) 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION TWO GENERAL REQUIREMENTS

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

2-4

Flowchart of Criteria for 

Substantial Harm 

Does the facility transfer oil over

water to or from vessels and does

the facility have a total oil storage

capacity greater than or equal to

42,000 gallons?

Does the facility have a total oil

storage capacity greater than or

equal to 1 million gallons?

No Submittal of Response Plan

Except at Regional

Administrator Discretion

Submit Response Plan

Within any aboveground storage tank area, does

the facility lack secondary containment that is

sufficiently large to contain the capacity of the

largest aboveground oil storage tank plus

sufficient freeboard to allow for precipitation?

Is the facility located at a distance

such that a discharge from the facility

could cause injury to fish and wildlife

and sensitive environments?

Is the facility located at a distance

such that a discharge from the facility

would shut down a public drinking

water intake?

Has the facility experienced a reportable

oil spill in an amount greater than or equal

to 10,000 gallons within the last 5 years?

No

No

No

Yes

Yes

Yes

Yes

Yes

No

No

No

1 Calculated using the appropriate formula in

 Attachment C-III to Appendix C in Title 40

 Code of Federal Regulations part 112 or a

 comparable formula.

2 For further description of fish and wildlife and

 sensitive environments, per Appendices I, II, and

 III to DOC/NOAA’s “Guidance for Facility and

 Vessel Response Plans: Fish and Wildlife and

 Sensitive Environments” (59 FR 14713. March

 29, 1994) and the applicable Area Contingency

 Plan.

3 Public drinking water intakes are analogous to

 public water systems as described at 40 Code of

 Federal Regulations 143.2(c).

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION TWO GENERAL REQUIREMENTS

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

2-5

2.4 AMENDMENT OF SPCC PLAN BY REGIONAL 

 ADMINISTRATOR [40 CFR 112.4] 

 Not withstanding compliance with Section 112.3, whenever the facility has a 

 discharge of oil in excess of 1,000 gallons in a single event, or two discharges occur 

 of more than 42 gallons within any 12-month period, the following information must 

 be submitted to the Regional Administrator of the EPA within 60 days from the time 

 of the incident: 

• Name of the facility; 

• Your name; 

• Location and phone number of the facility; 

• Maximum storage capacity of the facility and normal daily 

throughput; 

• Corrective action and countermeasures taken, including a 

description of equipment repairs and replacements; 

• Description of the facility, including maps, flow diagrams, and 

topographical maps as necessary; 

• The cause of the discharge, including failure analysis of the system 

or subsystem in which the failure occurred; 

• Additional preventive measures taken to minimize the possibility 

of recurrence; and 

• Any other information that the Regional Administrator may 

reasonably require as pertinent. 

2.5 NOTIFICATION OF STATE AGENCY [40 CFR 112.4(C)] 

Send to the state agency in charge of oil pollution control activities, a complete copy of all 

information provided to the Regional Administrator under paragraph (a) of this section 

shown above. The state agency may conduct a review of and make recommendations of the 

Regional Administrator as to further procedures, methods, equipment, and other 

requirements necessary to prevent and contain discharges from the facility. Notification 

should be provided to the following address: 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION TWO GENERAL REQUIREMENTS

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

2-6

Mississippi Emergency Management Agency 

(800) 222-6362 or (601) 352-9100 

24-hour Emergency Number 

2.6 NOTIFICATION OF FEDERAL AGENCY 

The National Response Center (NRC) will be notified by calling (800) 424-8802 in 

accordance with the requirements of 40 CFR 117 and 40 CFR 302 as soon as Bayou 

Casotte Energy knowledge of a discharge/release to the environment. 

Where appropriate, U.S. Environmental Protection Agency, Region 4 will also be 

notified at (404) 562-8700. 

The U.S. Coast Guard is the lead federal response agency for spills occurring in 

coastal waters, deep water ports, the Great Lakes, Mississippi River, and operates the 

National Response Center. EPA is the lead federal response agency for spills 

occurring in inland waters. 

2.7 AMENDMENT OF SPCC PLAN BY OWNER OR OPERATOR [40 

 CFR 112.5] 

This SPCC Plan shall be amended whenever there is a change in facility design, 

construction, operation, or maintenance practices which materially affects the 

facility's potential for the discharge of oil upon the navigable waters of the United 

States or adjoining shore lines. Such amendments shall be fully implemented as soon 

as possible, but not later than six months after such changes occur. 

Examples of changes that may require amendment of the Plan include, but are not 

limited to: commissioning or decommissioning containers; replacement, 

reconstruction, or movement of containers; reconstruction, replacement, or 

installation of piping systems; construction or demolition that might alter secondary 

containment structures; changes of product or service; or revision of standard 

operation or maintenance procedures at a facility. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION TWO GENERAL REQUIREMENTS

Bayou Casotte Energy LLC Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

2-7

Any such changes shall be noted on the Review and Amendment Log included within 

this SPCC plan. Any pages that require revision will be noted with the date of the 

change and will replace the existing page in this plan. An entry will be made in the 

Review and Amendment Log noting the date of the change, a general description of 

the changes that made the amendment necessary (an additional description of changes 

can be inserted as an attachment to the log, if necessary), pages affected, signature of 

the person making the changes, and noting whether the changes were significant 

enough to warrant re-certification by a P.E. 

 2.7.1 Plan Review [40 CFR 112.5(b)] 

The SPCC Plan shall be reviewed and evaluated at least once every five years. 

An entry shall be made in the Review and Amendment Log and signed after 

each review. If the plan is determined to be satisfactory through this review, 

then the entry shall note that no changes were made and will include the 

signature of the reviewer. Any changes to the plan made as a result of the 

scheduled review shall be made as soon as possible, but no more than six 

months from the time of the review. 

 2.7.2 Re-Certification [40 CFR 112.5(c)] 

Significant amendments to the plan will require re-certification by a P.E. in 

accordance with 112.3(d). If re-certification is necessary, a new certification 

page shall be sealed and signed and inserted into the plan. Administrative 

changes do not require re-certification, but still must be noted in the Review and 

Amendment Log. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION THREE General Requirements for SPCC Plan

Bayou Casotte Energy LLC 3-1 Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan

3.1 GENERAL FACILITY DESCRIPTION [40 CFR 112.7(A)(3)] 

The Casotte Landing Terminal will be located near the existing Chevron Pascagoula 

Refinery adjacent to the Bayou Casotte Channel in Jackson County, Mississippi. It is 

an onshore facility encompassing 4.8 square miles that is engaged in storing, 

processing, refining, transferring, and distributing crude oil and petroleum and 

petrochemical products. 

The Terminal will primarily be sited on the old Corning property that is now 

controlled by Chevron USA Inc. The site encompasses approximately 264 acres of 

land bounded by Bayou Casotte on the west, West Hardee Road on the North, Ranson 

Road on the East, and the Southern property line that runs along plant coordinate 

N844.24’. The grid reference point for the site plan is at N0985.90’ and E1508.10’. 

The geotechnical reference point established on the site is at N2284.07’ and 

E5264.45’. The plant coordinate system is identical to the NAD27 Mississippi State 

Plane East Zone coordinate system but with the first two digits (N24 & E60) omitted. 

 The Casotte Landing Terminal site includes the following process systems: 

• LNG Carrier Berth; 

• LNG off-loading arms; 

• LNG storage tanks; 

• Boil-Off-Gas (BOG) system; 

• NGL Extraction Plant; 

• LNG vaporization (Intermediate Fluid Vaporizers); 

• Heating systems; 

• Natural gas and NGL metering; 

• Flare system; 

• Wastewater system; 

• Storm water system; 

• Instrument air system; 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION THREE General Requirements for SPCC Plan

Bayou Casotte Energy LLC 3-2 Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan

• Nitrogen system; and 

• Other utility systems. 

Facilities and Buildings include: 

• Terminal control center, administration, warehouse, shop, and security 

building; 

• Main gate guard house; 

• Tug berth; 

• Construction barge dock; 

• LNG process impoundment basin; 

• LNG berth impoundment basin; 

• Terminal substations; 

• Mississippi Power Company substation; 

• LNG berth substation; 

• Cooling tower substation; 

• LNG berth control shack; and 

• Firewater pond and pump houses. 

3.2 EMERGENCY RESPONSE INFORMATION[40 CFR 112.7(A)(5)] 

 3.2.1 Written Commitment of Resources 

In addition to the spill prevention, control, and countermeasures described in 

this SPCC Plan, Bayou Casotte Energy also agrees to commit necessary 

manpower, equipment, and materials to control and remove any potentially 

harmful quantity of oil discharged in areas without secondary containment or 

into the municipal sewer system or storm water system during construction 

activities. 

 3.2.2 Spill Response Procedures and Corrective Measures 

Upon the finalization of the SPCC Plan prior to commencement of 

construction activities, Bayou Casotte Energy will develop project-specific 

procedures that will address the following areas: 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION THREE General Requirements for SPCC Plan

Bayou Casotte Energy LLC 3-3 Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan

• Identify key resources available for responding to an incident at the 

site; 

• Coordinate communications to potentially affected residents of the 

community; 

• Provide guidance, policies, and procedures, and assign duties, as 

necessary to appropriate personnel; and 

• Establish written procedures for implementation of this Construction 

SPCC Plan. 

All spill response procedures, immediate removal actions, and follow-up 

corrective actions will be coordinated through and supervised by the 

appropriate and qualified individuals. In no event will recovered spill product 

materials, contaminated soil, or other spill residues be improperly or illegally 

disposed. 

If a reportable spill should occur at the Casotte Landing Terminal, all required 

federal, state, and local spill reporting will commence immediately. 

 3.2.3 Prediction of Direction, Rate of Flow, and Quantity of Discharge 

[40 CFR 112.7(b)] 

The hypothetical events required by the regulations have been evaluated and a 

more detailed discussion and information will be provided prior to the Casotte 

Landing Terminal becoming fully operational. 

 3.2.4 Emergency Telephone Numbers 

In the event of an oil spill occurring at a time other than the normal work 

hours, the appropriate, qualified individual(s) will be contacted as soon as 

possible after the discovery of the spill or emergency. The qualified 

individual(s) will initiate the spill response in accordance to the Casotte 

Landing Natural Gas Import Terminal Emergency Response Plan (ERP). 

Emergency call outs shall follow procedures described in the ERP. A copy of 

the ERP will be maintained on site. The required organizations will be called 

based on the instructions contained in the Casotte Landing Natural Gas Import 

Terminal ERP. An updated contact list of plant personnel and the applicable 

emergency response notification procedures (i.e. spill assessment and call out 

procedures, agency information and spill reporting) will be provided in the 

ERP. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION THREE General Requirements for SPCC Plan

Bayou Casotte Energy LLC 3-4 Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan

3.3 DESCRIPTION OF CONTAINMENT AND DIVERSIONARY 

 STRUCTURES [40 CFR 112.7(C)] 

The Casotte Landing Terminal will implement ample secondary containment for 

designated storage areas and temporary storage containers, during construction 

activities. Secondary containment for each container will be documented within 

applicable Tables within this SPCC Plan. A description of each type of container, 

material of construction, approximate containment capacity, and predicted direction 

of runoff from the containment area will be included in this Plan upon prior to full 

operation of the Terminal. Secondary containment structures are not part of the 

permanent facility and will be removed at the completion of construction activities. 

It is unlikely that a spill to land would leave the Casotte Landing Terminal, but the 

Terminal will have oil spill response resources capable of cleaning up the largest 

estimated spills to water. Emergency spill equipment (i.e., spill kits) will be 

readily available at primary storage areas. Each kit will contain the necessary 

resources required to respond to an actual spill at the Terminal. 

Five key areas will require secondary containment measures during construction 

activities. Each area, and potential product storage (as applicable), are listed 

below. Secondary containment measures for these areas is described in Section 

3.3.1 

(1) Waste Storage Area 

• Waste Oil 

• Equipment Grease 

(2) Product Storage Area 

• Hydraulic Oil 

• Diesel 

• Gasoline 

• Lube Oil 

 (3) Chemical Storage Area 

• Cleaning Solvents 

• Paints and Thinners 

• Fiberglass Resin 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION THREE General Requirements for SPCC Plan

Bayou Casotte Energy LLC 3-5 Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan

• Fusion Bon Epoxy 

• Sack Crete 

• Sandblasting Material 

• Coal Tar Epoxy 

 (4) Fueling and Maintenance Area 

 (5) Loading/Unloading Area 

3.3.1 Secondary Containment 

Temporary equipment will be utilized (i.e., berms and liners) around 

aboveground storage tanks and designated areas of material storage. The 

temporary equipment will be capable of containing at least 110 percent of the 

largest container. Any storm water that may accumulate within the structure 

may be released following a visual inspection by qualified personnel, 

provided there is not evidence of a sheen, odor, etc. 

All fuel nozzles shall be equipped with automatic shut off valves. All 

applicable written procedures will be followed during fueling operations. In 

addition, prior to departure, all outlets will be inspected, tightened, and 

adjusted to prevent leakage while in transit. 

3.4 INSPECTIONS, TESTS, AND RECORDS [40 CFR 112.7(E)] 

Upon the Casotte Landing Terminal becoming fully operational, 

 inspections will be conducted in accordance with written procedures 

 developed by Bayou Casotte Energy and with applicable portions of API 

 653. Records will be maintained for five years. 

3.5 PERSONNEL, TRAINING, AND DISCHARGE 

 PREVENTION PROCEDURES [40 CFR 112.7(F)] 

Prior to the Casotte Landing Terminal becoming fully operational, personnel 

will receive extensive training on all aspects of the operation and maintenance 

of the Terminal. All Terminal operations and maintenance personnel will 

receive necessary training on Emergency Response procedures, including 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION THREE General Requirements for SPCC Plan

Bayou Casotte Energy LLC 3-6 Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan

annual refresher training. Management and other personnel who could be 

involved in any type of emergency will also receive training appropriate with 

their delegated responsibilities. 

All applicable plans will be immediately available for instructions and 

guidelines to be followed if an oil spill occurs. 

3.6 SECURITY [40 CFR 112.7(G)] 

The Casotte Landing Terminal will operate 24 hours a day, seven days a 

week. There will be access gates and guards that will control and regulate 

entrance 24 hours a day. The facility will be fully fenced, except where 

Terminal property is bounded by the coastline or marsh, where private 

property signs will be present. Lighting will be present throughout the 

footprint to provide illumination during hours of darkness. Additional 

lighting will be used in operating areas to facilitate spill discovery and 

operating activities at night. Lighting will be adequate to facilitate security 

and prevent vandalism at night. 

Tank drain valves located in process areas will remain closed during nonoperating or non-standby status. The tanks will be inside fenced areas with 

restricted entry. The loading/unloading connections will be secured, as 

necessary. Transfer pumps for these lines are also shut to the “off” position 

when not in service. 

The security requirements for the Terminal are governed by regulations 

promulgated by both the DOT and the USCG. An Interagency Agreement 

dated February 11, 2004, details the relationship among the USCG, the FERC, 

and the DOT-RSPA regarding security management issues at onshore LNG 

terminals. 

Under 49 CFR 193, DOT’s OPS is responsible for federal safety standards at 

onshore LNG facilities. This responsibility extends to requiring security 

training for facility personnel (49 CFR 193 Sections 2709 and 2715) and the 

implementation of various security measures, cameras, 24-hour-per-day, 7-

day-a-week (24/7) monitoring, security fences and gates, access control 

systems and trained security guards who will conduct facility patrols are 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION THREE General Requirements for SPCC Plan

Bayou Casotte Energy LLC 3-7 Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan

elements under consideration as development of a detailed security 

management plan continues to progress. 

In responding to the 33 CFR 105 requirements, Bayou Casotte Energy will 

develop an effective security plan that will incorporate detailed preparation, 

prevention, and response activities for each MARSEC Level, as well as 

identifying and training the personnel responsible for carrying all necessary 

security duties. Bayou Casotte Energy will be responsible, in terms of the 

Terminal, for designating and training a Facility Security Officer (FSO), 

ensuring that an FSA is conducted, developing and submitting for USCG 

approval an FSP, operating the facility in accordance with the approved FSP, 

providing appropriate security training for all Terminal personnel, 

implementing the necessary security measures applicable to the specific 

MARSEC Level in effect for the Port, reporting all breaches in security both 

internally and to appropriate governmental authorities, coordinating Terminal 

access for ship personnel and visitors to the ship, ensuring security for 

unattended vessels moored at the Terminal, and ensuring consistency between 

security and safety requirements. 

3.7 FACILITY TANK CAR AND TANK 

 UNLOADING/LOADING RACK (EXCLUDES 

 OFFSHORE FACILITIES) [40 CFR 112.7(H)] 

40 CFR 112.7(h) is not applicable to the operations that will be conducted at 

the Casotte Landing Terminal during construction activities. 

3.8 CONFORMANCE WITH OTHER APPLICABLE 

 GUIDELINES [40 CFR 112.7(J)] 

No additional guidelines have been identified as it relates to conformance 

with the applicable requirements and other effective discharge prevention 

and containment procedures listed in this part or any applicable more 

stringent State rules, regulations, and guidelines. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION FOUR SUBPART B: SPCC PLAN REQUIREMENTS FOR 

 ONSHORE FACILITIES

Bayou Casotte Energy LLC 4-1 Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

4.1 FACILITY DRAINAGE [40 CFR 112.8(B)] 

Drainage from diked storage areas will be inspected prior to release, to ensure that 

sheen is not observed. In addition, manually operated valves will normally be kept in 

the closed and locked position, so as to ensure that a release does not occur prior to 

inspection. Drainage from diked areas will be retained in an emergency retention 

pond. Water quality will be assessed to ensure compliance with NPDES permit limits 

before being discharged. Water will be discharged through manually operated valves 

kept in the closed position. When a discharge is complete, the valves are returned to 

the closed position. 

 Upon the Casotte Landing Terminal becoming operational, process water will be 

captured and treated accordingly throughout the operations of the Terminal. There 

are four major waste streams: (1) Non-contact stormwater; (2) Contact stormwater 

(oily water); (3) Gray water (domestic uses); and (4) Black water (sanitary water). 

These waste streams will be treated and released in accordance with the NPDES 

permit (as administered by the Mississippi Department of Environmental Quality 

(MDEQ)). 

Bayou Casotte Energy has designed the Terminal storm water system to carry storm 

water by surface ditches and swales that runs alongside of the roads and along the 

heels of the hurricane levees. The storm water will then be collected through a series 

of catch basins located throughout the site. Storm water collected inside of the 

hurricane levee will be pumped over the hurricane levee to the storm sewer systems 

outside of the levee. Underground sewer pipes will be used to connect catch basins 

outside of the levee. Two header sewer pipes at the north and the south side of the 

process area will carry the storm water to two new outfalls into Bayou Casotte. 

4.2 BULK STORAGE TANKS [40 CFR 112.8(C)] 

During construction activities, product, waste, and chemicals will be present at the 

Terminal, as described in Section 3.3. Prior to commencement of construction 

activities, and upon finalization of this Plan by the construction contractor, a list of all 

materials, container, and storage description will be submitted. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
SECTION FOUR SUBPART B: SPCC PLAN REQUIREMENTS FOR 

 ONSHORE FACILITIES

Bayou Casotte Energy LLC 4-2 Draft Construction 

Spill Prevention, Control, and 

Countermeasures (SPCC) Plan 

There are no underground storage tanks (USTs) in operation at the Casotte Landing 

Terminal. 

There are no partially buried tanks located at the Casotte Landing Terminal. 

Operating personnel will routinely monitor tanks in their area of responsibility for 

integrity and check for any leaks. 

When portable tanks are used, they are positioned or located so as to prevent spilled 

oil from reaching navigable waters. The containers will be inspected on a regular 

basis for leaks. 

4.2.1 Brittle fracture evaluation requirements [40 CFR 112.7(i)] 

All tanks at the Casotte Landing Terminal are expected to be in new 

condition, and will be designed to have adequate resistance to brittle fracture 

at the lowest ambient temperature per API 650 (or corporate equivalent). All 

repairs and alterations will be conducted to the applicable standards of API 

653, and will be completed with materials that will not impact the tank’s 

resistance to brittle fracture. 

4.3 FACILITY TRANSFER OPERATIONS, PUMPING, AND FACILITY PROCESS 

 [40 CFR 112.8(D)] 

Upon installation of piping at the Casotte Landing Terminal, buried piping will have 

adequate protective wrapping and/or coating to prevent corrosion. Buried piping 

exposed for any reason will be inspected for corrosion and repairs will be made as 

needed ensuring adequate corrosion protection. Cathodic protection will be installed 

where appropriate. 

Casotte Landing Terminal pipelines shall be identified by stenciled lettering. Pipe 

supports meet Casotte Landing Natural Gas Import Terminal Standards that meet 

or exceed industrial standards.

Aboveground valves and pipelines will be visually examined routinely by qualified 

individual(s). Hydrostatic testing or equivalent U.S. DOT-approved integrity testing, 

will be performed on a pipeline before it is initially put into service and typically 

prior to a pipeline put in service after repairs have been made. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
TABLES 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
FIGURES 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDICES 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX E1 

SECTION 103 EVALUATION 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
BAYOU CASOTTE ENERGY LLC

CASOTTE LANDING 

NATURAL GAS IMPORT 

TERMINAL PROJECT

CASOTTE LANDING SLIP SEDIMENT 

EVALUATION REPORT – ODMDS 

SUITABILITY

JULY 13, 2006

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Prepared for: 

Bayou Casotte Energy LLC 

Casotte Landing Slip Sediment 

Evaluation Report – ODMDS Suitability 

ENSR Corporation 

July 13, 2006 

Document No.: 01231-021-0049 

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Contents 

1.0 Introduction............................................................................................................................................... 1-1

1.1 Site History ...................................................................................................................................... 1-1

1.2 Soil/Sediment Evaluation ................................................................................................................ 1-2

2.0 Methods..................................................................................................................................................... 2-1

2.1 Field sampling ................................................................................................................................. 2-1

2.1.1 Soil collection ..................................................................................................................... 2-1

2.1.2 Sediment collection............................................................................................................ 2-2

2.1.3 Surface water collection .................................................................................................... 2-2

2.2 Sample processing and analysis .................................................................................................... 2-2

2.2.1 Phased testing ................................................................................................................... 2-2

2.2.2 Core and excavation sample handling.............................................................................. 2-3

2.2.3 Test sample preparation and pooling................................................................................ 2-3

2.2.4 Physical and chemical sample analysis............................................................................ 2-3

2.2.5 Elutriate/suspended particulate phase sample preparation............................................. 2-4

2.2.6 Tissue sample preparation................................................................................................ 2-5

2.3 Data analysis ................................................................................................................................... 2-5

2.3.1 Sediment screening levels ................................................................................................ 2-5

2.3.2 Sediment reference comparisons ..................................................................................... 2-6

2.3.3 Toxicity bioassay statistics ................................................................................................ 2-6

2.3.4 STFATE modeling ............................................................................................................. 2-6

2.3.5 BSAF calculations.............................................................................................................. 2-7

2.3.6 Bioaccumulative tissue statistics....................................................................................... 2-7

3.0 Project field effort..................................................................................................................................... 3-1

3.1 Mobilization and navigation............................................................................................................. 3-1

3.2 Sample transfers ............................................................................................................................. 3-1

3.3 SAP deviations and difficulties encountered .................................................................................. 3-2

4.0 Results and discussion........................................................................................................................... 4-1

4.1 Sediment physical, chemical and toxicity characteristics .............................................................. 4-1

4.1.1 Sediment texture................................................................................................................ 4-1

4.1.2 Sediment chemistry ........................................................................................................... 4-2

4.1.3 Whole sediment toxicity..................................................................................................... 4-4

4.2 Water column evaluations............................................................................................................... 4-8

4.2.1 Elutriate chemistry ............................................................................................................. 4-8

4.2.2 SPP bioassay results......................................................................................................... 4-8

4.3 Bioaccumulation potential ............................................................................................................... 4-9

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
4.3.1 BSAF findings .................................................................................................................. 4-10

4.3.2 28-day bioaccumulation bioassay................................................................................... 4-10

5.0 Conclusions and MPRSA Section 103 considerations....................................................................... 5-1

5.1 Sediment exposure ......................................................................................................................... 5-1

5.2 Water column effects....................................................................................................................... 5-2

5.3 Bioaccumulation findings ................................................................................................................ 5-2

5.4 Conclusions ..................................................................................................................................... 5-3

6.0 Project QA/QC findings ........................................................................................................................... 6-1

6.1 Biological testing QA/QC................................................................................................................. 6-1

6.1.1 Whole sediment toxicity bioassays ................................................................................... 6-1

6.1.2 Suspended particulate phase bioassays .......................................................................... 6-2

6.1.3 Reference toxicants........................................................................................................... 6-2

6.1.4 Protocol Deviations............................................................................................................ 6-3

6.1.5 28-day sediment bioassay/bioaccumulation tests............................................................ 6-3

6.2 Chemical analyses QA/QC ............................................................................................................. 6-4

6.2.1 Analytical sensitivity........................................................................................................... 6-4

6.2.2 Contamination concerns.................................................................................................... 6-4

6.2.3 Data precision.................................................................................................................... 6-5

6.2.4 Data accuracy.................................................................................................................... 6-6

7.0 References ................................................................................................................................................ 7-1

Attachment 1 Amphipod Evaluation Transmittal 27 March 2006 

Attachment 2 Water Column Evaluations, Numerical Model (STFATE) Input Parameters 

APPENDICES (provided on CDs) 

A FIELD LOGS 

B GRAIN SIZE DATA 

C CHEMISTRY DATA 

 C1 – CHEMISTRY LABORATORY DATA 

 C2 – DATA VALIDATION FINDINGS 

D TOXICITY LABORATORY DATA 

E ANCILLARY PROJECT DATA 

F STFATE INPUT AND OUTPUT FILES 

Q:\mw97\Projects\01231021\0049\All_Final.doc ii July 2006

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
List of Tables 

Table 2-1 Collection Dates and Testing Specifications for Soil / Sediment Samples 

Table 2-2 Available Sediment Screening ERL and ERM Levels 

Table 2-3 STFATE Model Input Parameters for Disposal in Zone B of the Pascagoula ODMDS 

Table 3-1 Summary of Field Activities 

Table 3-2 Soil/Sediment and Water Collection Coordinates 

Table 4-1 Agency Provided Sample Analysis Recommendations 

Table 4-2 CLLNG Phase 1 Chemistry and Grain Size Results 

Table 4-3 CLLNG Phase 2 Chemistry and Grain Size Results 

Table 4-4 Casotte Landing Sediment Aluminum to Metal Regression Coefficients (Phase 2) 

Table 4-5 Regional NOAA National Status and Trends Comparison Sites 

Table 4-6a Casotte Landing Whole Sediment Bioassay Findings – Americamysis bahia Survival 

Table 4-6b Casotte Landing Whole Sediment Bioassay Findings – Leptocheirus plumulosus Survival 

Table 4-6c Casotte Landing Whole Sediment Bioassay Findings – Leptocheirus plumulosus Survival – 

Acclimated and Supplemented Treatment 

Table 4-7a Whole Sediment Bioassay Statistical Findings – Americamysis bahia

Table 4-7b Whole Sediment Bioassay Statistical Findings – Leptocheirus plumulosus – Acclimated and 

Supplemented Treatment 

Table 4-8 CLLNG Elutriate Chemistry 

Table 4-9 CLLNG Elutriate Chemistry Comparison to State and Federal Water Quality Criteria and 

Required Dilution Factors 

Table 4-10a Standard SPP Bioassay Findings – Americamysis bahia Percent Survival Results 

Table 4-10b Standard SPP Bioassay Findings – Menidia beryllina Percent Survival Results 

Table 4-10c Standard SPP Bioassay Findings – Arbacia punctulata Percent Survival and Percent Normal 

Development Results 

Table 4-11 Median Lethal Concentration Calculation Summary 

Table 4-12a Standard SPP Bioassay Supporting Statistics – Americamysis bahia Percent Survival Results 

Table 4-12b Standard SPP Bioassay Supporting Statistics – Menidia beryllina Percent Survival Results 

Q:\mw97\Projects\01231021\0049\All_Final.doc iii July 2006

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Table 4-12c Standard SPP Bioassay Supporting Statistics – Arbacia punctulata Percent Survival Results 

Table 4-13 Agency Recommended Tissue Analysis Scope 

Table 4-14 Casotte Landing Station SB7U Biota to Sediment Accumulation Factors 

Table 4-15a 28-Day Bioassay Survival – Macoma nasuta Percent Survival Results 

Table 4-15b 28-Day Bioassay Survival – Nereis virens Percent Survival Results 

Table 4-16 Tissue Chemistry Results – Macoma nasuta (Wet Weight) 

Table 4-17 Tissue Chemistry Results – Nereis virens (Wet Weight) 

Table 4-18 Food and Drug Administration Action Levels for Edible Fish and Shellfish 

Table 4-19 Mercury Tissue Upper Confidence Limit Test Results (Wet Weight) 

Table 4-20 Tissue Exposure Comparisons for Detected Analytes – Macoma nasuta (Wet Weight) 

Table 4-21 Tissue Exposure Comparisons for Detected Analytes – Nereis virens (Wet Weight)

Table 4-22 Bioaccumulation Significance Testing – Tissue Concentrations Statistically Greater at Site vs 

Reference 

Table 4-23 Mean Tissue Concentrations Associated with Results that are Statistically Greater than 

Reference (Wet Weight) 

Table 4-24 Critical Body Residue Concentrations 

Q:\mw97\Projects\01231021\0049\All_Final.doc iv July 2006

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
List of Figures 

Figure 1-1 CLLNG Slip Location 

Figure 1-2 CLLNG Slip Area and 1940 Land Features 

Figure 1-3 CLLNG Slip Area with Terminal Slip Footprint and Solid Waste Management Units 

Figure 2-1 Proposed and Actual Soil and Sediment Sampling Locations 

Figure 2-2 Reference Sediment Location 

Figure 2-3 Inshore and Offshore Water Sample Locations 

Figure 3-1 Sampling Pit and Soil / Sediment Core Collection Intervals, with Fill Layers 

Figure 4-1 Casotte Landing Phase 2 Sediment Grain Size 

Figure 4-2 Example Metal to Aluminum Regression Findings 

Figure 4-3 Chemical Ratios-to-Reference: Metals 

Figure 4-4 Chemical Ratios-to-Reference: Non-Metals 

Figure 4-5 Chemical Ratios-to-Reference: PAH Compounds 

Figure 4-6 NOAA National Status and Trends Sediment Monitoring Stations 

Figure 4-7 Comparison of Metals in CLLNG Sediments to National Status and Trends and Grand Bay 

Reference Sediments 

Figure 4-8 Comparison of PAHs, PCBs, and Pesticides in CLLNG Sediments to NS&T and Grand Bay 

Reference Sediments 

Figure 4-9 Example Amphipod Test Chamber 

Figure 5-1 STFATE Model Results for 3,000 and 5,000 cy Barge – No Overflow Scenario 

Q:\mw97\Projects\01231021\0049\All_Final.doc v July 2006

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Q:\mw97\Projects\01231021\0049\All_Final.doc 1 July 2006

ACRONYMS 

ADDAMS - Automated Dredging and Disposal Alternatives Management System 

AET - Apparent Effects Threshold 

AL - Action Level 

ANOVA - Analysis of Variance 

BGS - Below Ground Surface 

BSAF - Biota to Sediment Accumulation Factor 

CBR - Critical Body Residue 

CDF - Confined Disposal Facility 

CE SAM - U.S. Army Corps of Engineers Mobile District 

CLLNG - Casotte Landing Liquified Natural Gas 

COC - Chain-of-Custody 

CY - Cubic Yards 

DGPS - Differential Global Positioning System 

EPA - U.S. Environmental Protection Agency 

ERDC - Engineering Research and Development Center (USACE) 

ERL - Effects Range-Low 

ERM - Effects Range-Median 

ERLQ - Effects Range-Low Quotient 

ESI - EnviroSystems, Inc. 

FDA - Food and Drug Administration 

FSP - Field Sampling Plan 

GC - Gas Chromatograph 

LPC - Limiting Permissible Concentration 

MCY - Million Cubic Yards 

MLLW - Mean Lower Low Water 

MPRSA - Marine Protection Research and Sanctuaries Act 

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
ND - Not Detected 

NOEC - No-Observed-Effect Concentration 

NS&T - National Status and Trends 

ODMDS - Ocean Dredged Material Disposal Site 

PAH - Polynuclear Aromatic Hydrocarbon 

PCB - Polychlorinated Biphenyl 

QAPP - Quality Assurance Project Plan 

RL - Reporting Limit 

RTR - Ratio to Reference 

SAP - Sampling and Analysis Plan 

SOW - Scope of Work 

SPP - Suspended Particulate Phase 

STFATE - Short Term FATE Numerical Model 

SWMU - Solid Waste Management Unit 

TAT - Turn-Around Time 

TOC - Total Organic Carbon 

TPH - Total Petroleum Hydrocarbons 

USACE - U.S. Army Corps of Engineers 

VOC - Volatile Organic Carbon 

WQC - Water Quality Criteria 

WQS - Water Quality Standards 

Q:\mw97\Projects\01231021\0049\All_Final.doc 2 July 2006

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Executive Summary 

Bayou Casotte Energy LLC, a subsidiary of Chevron U.S.A., Inc. (CUSA), proposes to build and operate an 

onshore liquefied natural gas (LNG) import terminal and associated facilities south of the existing CUSA 

Pascagoula Refinery on Bayou Casotte, just east of Pascagoula, Mississippi. The proposed Casotte Landing 

Natural Gas Import Terminal Project includes the construction of a new double-berth slip for accommodation of 

an LNG Berth and the relocation of an existing refinery berth for the Pascagoula Refinery along the eastern 

shore of Bayou Casotte. 

Creation of the slip will require removal of approximately 4.5 million cubic yards (mcy) of material. A large 

portion (ca. 1 mcy) of the upper soil material will be excavated and used on-site for construction purposes. 

The remaining material (ca. 3.5 mcy) will be dredged and placed at one of the locations under consideration 

for the project. This study was performed to support agency decision-making related to the suitability of 

Casotte Landing slip material for placement at the Pascagoula Offshore Dredged Material Disposal Site 

(ODMDS). 

An agency-approved Sampling and Analysis Plan (SAP) was distributed to the project team in November, 

2005 and incorporated all chemical, physical, and biological testing required by CE SAM and EPA to make a 

suitability determination under the MPRSA Section 103. 

While suitability of the material for offshore placement will ultimately be decided by CE SAM and EPA, the bulk 

sediment evaluations conducted in this study provide a large weight-of-evidence that the material to be 

dredged is clean from a chemical perspective. Further, bioassay test organisms appear to be healthy after 

exposure tests, although given the unique low biogenic carbon sediment content, the material may not provide 

a sufficient food source for deposit feeders at the ODMDS until biogenic particles, raining down from the 

overlying water column, accumulate on the sediment surface for some weeks or months. 

Water column suspended particulate phase (SPP) bioassay tests, often the most sensitive indicators of 

biological effects, measured very good survival and development results by the time SPP mixtures were 

diluted in half. Water column (STFATE) simulations predict that limiting permissible concentrations (LPCs) 

would be reached well within the allowed 4-hour threshold and that related water column plumes would not 

travel very far. 

Lastly, because of the relatively clean nature of the site overall, only a few stations required further evaluation 

of potential bioaccumulative concerns. Of the many parameters measured, only six were at concentrations 

statistically greater than those of reference-exposed and pre-exposed tissue levels, but were nonetheless 

measured at very low concentrations and well within available No Observed Effect Concentration (NOEC) 

levels for aquatic organisms. 

The many evaluations conducted in this study provide a large weight-of-evidence that exposure to the Casotte 

Landing sediment dredged from the slip area will have little or no biological effect on the marine environment 

at the ODMDS and will provide a firm basis for agency decision-making. 

Q:\mw97\Projects\01231021\0049\All_Final.doc ES-1 July 2006

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
1.0 Introduction 

Bayou Casotte Energy LLC (BCE), a subsidiary of Chevron USA, proposes to build and operate an onshore 

liquefied natural gas (LNG) import terminal and associated facilities south of the existing Chevron Pascagoula 

Refinery on Bayou Casotte, just east of Pascagoula, Mississippi in Jackson County. The proposed Casotte 

Landing Natural Gas Import Terminal Project includes the construction of a new double-berth slip to 

accommodate LNG tankers and the relocation of an existing berth for the Pascagoula Refinery along the 

eastern shore of Bayou Casotte (Figure 1-1). The slip would be constructed to a depth of 46 feet below mean 

lower low water (MLLW) including advanced maintenance and overdepth dredging by cutting in from the 

existing navigation channel. 

Creation of the slip will require removal of approximately 4.5 million cubic yards (mcy) of material. A large 

portion (ca. 1 mcy) of the upper soil material will be excavated and used on-site for construction purposes. 

The remaining material (ca. 3.5 mcy) will be dredged and placed at one of the locations under consideration 

for the project. The purpose of this investigation is to evaluate the suitability of the soil and sediment material 

to be removed for placement at the Pascagoula ODMDS (ODMDS) located to the south of Horn Island. This 

evaluation follows guidelines provided by the United States Army Corps of Engineers (USACE) and the United 

States Environmental Protection Agency (EPA) (EPA/USACE, 1991; EPA/USACE, 1993) to ensure that 

coastal waters are protected from any potential adverse effects as specified under Section 103 of the Marine 

Protection Research and Sanctuaries Act (MPRSA). 

1.1 Site History 

Before industry moved into the area around 1960, the proposed Casotte Landing LNG (CLLNG) slip area was 

largely aquatic as depicted in Figure 1-2. During the 1950’s the slip area was filled, apparently with material 

dredged from Bayou Casotte as a way to establish what was then the largest industrial site in the state 

(Goodwin and Associates, 2005; Sullivan, 1985). 

The slip area and larger LNG terminal site were initially occupied by Corning Glass Works (formerly Cohart 

Refractory), where high temperature brick was manufactured at the site until 1989 using a magnesite 

refractory process. A landfill and two settling ponds/lagoons were established and used on the site by 

Corning/Cohart Refractory while they occupied the site (Figure 1-3). The landfill was an unlined facility used to 

store waste generated during the manufacturing process (Solid Waste Management Unit [SWMU] 5 on 

Figure 1-3). The material discarded included red furnace dust containing chromium, sand containing 

chromium, chrome ore, lime, concrete rubble, scrap metal, and wood. In 1984, the landfill waste was 

excavated and disposed of offsite and the site was backfilled with a mixture of soil and refractory brick debris. 

Two unlined surface impoundments were also established and used as settling ponds for wastewater 

containing fines southeast of the slip area (SWMU 14 on Figure 1-3). The fines contain elevated 

concentrations of Cr, Mg, Ni, Pb and lime waste. Dolomite, a magnesium rich limestone, was used as the raw 

material for magnesium recovery in the refractory process. As a result, lime waste is abundant within the 

former lagoon. The lagoons covered a combined area of 6 acres. The north lagoon averaged 6 feet deep. 

The south lagoon averaged 3 feet deep. Both lagoons were removed from service in 1989, filled with lime and 

capped (URS, 2005). After investigation of soil and water contamination issues, the site was issued a “No 

Further Action” status by the U.S. Environmental Protection Agency (USEPA) circa 1989. Before initiating the 

slip construction, fill material contained in these former settling ponds will be excavated and transported to a 

permitted RCRA Subtitle D (Solid Waste) facility as part of site preparation. 

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
1.2 Soil/Sediment Evaluation 

To understand the suitability of material for offshore placement, a tiered approach is recommended by agency 

guidance. The process begins with a review of existing data, followed by modeling and detailed testing of the 

material. Testing results provide the information needed to understand potential biological effects that could 

occur at the ODMDS in the benthic sediments, in the water column, and within the food web. In this program, 

many of the tiers have been applied simultaneously to expedite the overall project schedule and to provide 

greater weight-of-evidence for the decision making. 

In 2005, BCE initiated a program to evaluate site soils and sediments, through its contractor ENSR, to collect 

the necessary information to understand the suitability of the material for various placement options including 

beneficial uses, placement in a confined disposal facility (CDF), and placement at the ODMDS. This 

document presents all project details and findings related to ODMDS suitability. Project soils and sediments 

were also evaluated under several earlier efforts (URS, 2005a; URS, 2005b). Data from those efforts were 

useful in developing the sampling plan for the current effort and are summarized in Field Sampling Plan and 

Quality Assurance Project Plan Supporting Casotte Landing Slip Dredged Material CWA/MPSRA Suitability 

Testing (ENSR, 2005). 

Q:\mw97\Projects\01231021\0049\All_Final.doc 1-2 July 2006

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Appendix E-1 page 14 

Figure 1-1 CLLNG Slip Location

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Appendix E-1 page 15 

Figure 1-2 CLLNG Slip Area and 1940 Land Facilities

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Appendix E-1 page 16 

Figure 1-3 CLLNG Slip Area with Terminal Slip Footprint and 

Solid Waste Management Units

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
2.0 Methods 

Field and laboratory methods are detailed in the project Sampling and Analysis Plan (SAP), comprised of a 

field sampling plan (FSP) and a quality assurance project plan (QAPP). These documents are included by 

reference (ENSR, 2005). Brief summaries of the methods used are included in the following subsections. 

2.1 Field sampling 

Project sampling sites were located in a grid-like fashion to represent the slip material while including side-wall 

and main facility locations. The final sampling design was approved by the USACE Mobile District (CE SAM) 

and the EPA Region 4. Sediment and soil samples were collected from 15 stations to characterize the 

material proposed for placement at the ODMDS (Figure 2-1). Twelve stations were distributed throughout the 

portion of the slip area that was historically filled and is currently upland (SB1 - SB12). Two of these stations 

were selected based on their proximity to ditches that traverse the slip area, two were located within the 

historical landfill (SWMU 5), and one was located within the former settling pond that intersects the area 

(SWMU 14) to evaluate any possible contaminant migration into underlying soil. Sediment was collected from 

three stations located in the submerged portion of the slip area (SC1 - SC3 in Figure 2-1). 

The field program objective was to collect representative samples needed to evaluate the potential 

contamination pathways related to placement at the ODMDS. This included the following three primary 

pathways: 

• Direct exposure to the dredged material following placement (bulk soil/sediment); 

• Direct exposure to the water column during/after mixing (elutriate and particulate phase analysis); and 

• Bioaccumulation potential resulting from dredged material exposure over a period of time 

(bioaccumulation bioassays followed by tissue analysis). 

Sampling efforts included soil and sediment coring, sampling pit excavations, sediment grabs and surface 

water collections. Appendix A includes the field logs associated with these efforts. 

2.1.1 Soil collection 

The soil column was stratified, with a surficial fill layer varying in thickness from 0 to 14 feet, but generally less 

than 10 feet. Beneath the fill was a sandy layer, underlain by a mixture of clay, silt and sand. Because the 

surficial fill layer will be used for on-site construction and will not be placed at the ODMDS, this material was 

not sampled or tested. The sandy and underlying clayey layers were designated as “upper” and “lower” layers, 

respectively, and analyzed separately. 

Soils were collected in the upland area using 2 approaches. Initially, cores were collected at each station 

using rotosonic drilling technology to the project depth of -46 feet MLLW. However, the upper sandy layer was 

thinner than expected and so sampling pits were excavated to collect large volume samples from this sand 

horizon. As-cored or as-dug sample positions were determined using a Trimble Pro-XRS DGPS (differential 

global positioning system). 

Site elevations ranged from 8 to 14 feet above MLLW and so the soil cores were generally collected to a depth 

of 60 feet below ground surface (bgs). Continuous sampling from land surface to the desired depth was 

accomplished using a five foot split core barrel containing clear plastic Lexan liners. Five foot sub-cores were 

then transferred intact to the core processing facility. Sampling pits were excavated using a track hoe with a 

reach of approximately 17 to 20 feet and a bucket capacity of about 1 cubic yard (cy). Excavated samples 

were contained in 5-gallon buckets for delivery to the processing facility. 

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All soil collection equipment was steam cleaned between collection stations as detailed in the project SAP. An 

equipment blank was collected from the rotosonic equipment and the excavator bucket once during the field 

effort. Project samples were placed in refrigerated storage on site during the field effort and transported to the 

processing facility/biological testing laboratory using refrigerated trucking services. Table 2-1 summarizes the 

sample testing prescribed for individual and composite stations. 

2.1.2 Sediment collection 

Sediment was collected from the subtidal slip area in water depths ranging from 1 to 15 feet below MLLW 

using vibracoring equipment. Full-length sediment cores were collected at each of the three aquatic stations 

and ranged in length from 36 to 40 feet. Cores were contained in Lexan liners and cut into five foot sections, 

sealed, and placed in refrigerated storage until transported under refrigeration to the core-processing facility. 

Reference sediment samples were collected from Grand Bay using a 0.1 m2 stainless steel GOMEX box core 

(Figure 2-2). The samples were dispensed to 5-gal collection buckets and transferred to the processing lab for 

subsequent homogenization and analysis. Based on the initial reference results, agencies (CE SAM, EPA) 

recommended that another sample be collected from the site in March 2006. 

Navigational positioning for the reference sediment sampling was accomplished using a Garmin 2010 DGPS 

integrated with PC-based HYPACK hydrographic software. The navigation system provided a real-time 

display of vessel position on an electronic nautical chart and provided the vessel operator with range and 

bearing information to pre-selected waypoints for accurate positioning and station-keeping during the sample 

collection process. The stated accuracy of the system is +/-1 meter. 

2.1.3 Surface water collection 

Water needed for elutriate chemistry and bioassay testing was collected from the ODMDS and Bayou Casotte 

at 1 meter depth using a 12-volt Teflon diaphragm pump and a suitable length of composite tubing (CFlexTM) 

(Figure 2-3). Water for background chemistry measurements was dispensed directly from the pump system to 

storage containers and water for bulk elutriate/bioassay samples was dispensed directly to plastic cube 

containers. 

Navigational positioning for the surface water collection was accomplished in the same manner as for 

reference sediment sampling. 

2.2 Sample processing and analysis 

The project QAPP provides detailed descriptions of all aqueous, sediment, soil and tissue sample handling 

and the methods used for chemical, physical and biological testing. Tables A-3 through A-5 of the QAPP 

summarize the chemical and physical testing methods used. Section B.4.6 of the QAPP summarizes the 

bioassay and bioaccumulation test methods. 

2.2.1 Phased testing 

Testing was conducted in two phases. The first phase provided CE SAM and EPA Region 4 with rapid 

soil/sediment chemistry and grainsize results to enable the agencies to develop a pooling scheme for 

subsequent testing. The second phase represented full scale testing of the site material including physical and 

chemical testing, toxicity bioassays, and bioaccumulation bioassays, all performed on the same sample 

homogenates. 

Because the upper sandy layer was thinner than expected, limited volume of this stratum was collected during 

the coring effort. For this reason, cored upper material was only used for the rapid Phase 1 testing exercises. 

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The large volume of excavated material (from sampling pits) was used for the full scale testing in Phase 2 of 

the analytical program. Based on Phase 1 chemistry results, Phase 2 samples were not analyzed for VOCs. 

2.2.2 Core and excavation sample handling 

At the core processing laboratory, the five foot soil/sediment sub-cores were split and subsampled. Core 

sections were split length-wise using an electric stainless steel shearing device. Two (opposing) cuts were 

made in the hard plastic and a plastic filament was pulled through the core material to separate the core into 

two halves. VOC subsamples were collected without delay using the criteria detailed in Section B.4.1 of the 

project QAPP. After VOC subsamples were collected and preserved, each 5-foot core section was visually 

classified and logged (Appendix A). EnCoreTM sampling devices were replaced with pre-preserved VOA vials 

containing sodium bisulfate and methanol to allow weekend sample shipment without exceeding preservation 

holding times. 

Each core or set of cores representing the depth interval of interest was scraped along the entire interval and 

homogenized to obtain a depth-integrated subsample. This subsample was then transferred to the testing 

laboratories for rapid chemical and physical testing (Phase 1 testing). The remaining core material was placed 

in 5-gal plastic buckets and refrigerated until pooling decision-making was complete. 

Sampling pit material was visually described at the site during the excavation process, homogenized in the 

excavator bucket using carbon steel shovels, and placed directly into 5-gal plastic buckets for refrigerated 

storage. Samples were further homogenized at the processing laboratory before testing. 

2.2.3 Test sample preparation and pooling 

Following the compositing recommendations made by CE SAM and EPA Region 4, soil/sediment composites 

were prepared at ESI by combining equal volumes of the material from the various stations to be composited. 

Material was dispensed from the 5-gallon buckets into a plasticized trough and raked using an unpainted 

carbon steel rake until the samples were fully blended. Individual Phase 2 sampling locations not included in 

composite samples were homogenized using the same methods. The composites or individual samples were 

then split and subsamples transferred to the physical and chemical testing laboratories. The remaining 

material was retained at the biological laboratory for subsequent bioassay and bioaccumulation testing. In 

each case under Phase 2 testing, chemical, physical, and biological testing was performed on the same 

sample homogenate. 

Ten-day whole sediment bioassays were conducted in accordance with EPA/USACE guidance for the South 

Atlantic Division (USACE/EPA, 1993), the Inland Testing Manual (EPA/USACE, 1998), and the project QAPP 

(ENSR, 2005). The 10-day whole sediment bioassays were conducted with the amphipod (Leptocheirus 

plumulosus) and the mysid shrimp (Americamysis bahia). Additional L. plumulosus testing was conducted to 

evaluate the potential impact of the sterile nature of the tested material containing a very limited food source 

and to assess the unusually low survival observed in the Grand Bay reference sediment. A framework for this 

additional testing was approved by EPA and USACE in a technical memorandum dated March 27, 2006 

(Attachment 1). 

2.2.4 Physical and chemical sample analysis 

Physical and chemical analysis methods are fully detailed in the project QAPP. In some cases, specialized or 

modified methods were specified to accommodate unique project objectives. A description of the specialized 

or modified methods is also provided in this section. 

A hydrofluoric acid (HF) digestion procedure (EPA SW-846 method 3052) was used to produce total sample 

decomposition of the soil/sediment samples prior to their analysis for Al by inductively coupled plasma-atomic 

emission spectroscopy (ICP-AES). The HF digestion procedure involved adding hydrochloric acid, nitric acid 

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and hydrofluoric acid to the solid sample in a Teflon vessel and heating it for two hours. These procedures 

allowed for analysis of total Al, which was used to normalize metals data for data synthesis. 

Soil/sediment samples were analyzed for ammonia, total Kjeldahl nitrogen (TKN), nitrate, nitrite, nitrate/nitrite, 

and total phosphorous using aqueous EPA methods that were modified by the laboratory for solid matrices. 

TKN digestions were performed by adding the solid matrix directly to the TKN apparatus; remaining nitrogen 

and phosphorous parameters were extracted, filtered and analyzed using the method-specified 

instrumentation. 

EPA SW-846 method 8082 is specifically set up for measuring PCB Aroclors and consequently requires 

modification for application to congener analysis. EPA SW-846 method 8082 used for PCB congener analysis 

of soils/sediments was modified by using standards made from individual congeners. Furthermore, while 

Aroclor quantitation is based on multiple peak pattern analysis, congeners were quantified from individual 

chromatogram peaks. 

Seawater samples analyzed for all metals, except Cr6+, Hg, and Se, were first subjected to a reductive 

precipitation technique to separate the analytes of interest from the interfering matrix that contained high levels 

of total dissolved solids. The samples were treated with iron and palladium followed by sodium borohydride as 

a reductant. The resulting precipitate effectively scavenged the analytes of interest from the solution, which 

were then redissolved in an acid matrix as detailed in EPA Method 1640. An inductively coupled plasma-mass 

spectrometer (ICP-MS) was then used for the analysis of the precipitated metals. 

EPA SW-846 method 7742 (hydride generation) was used for the analysis of selenium in the seawater 

samples. For this method, the samples were heated in a Teflon vessel for two hours with nitric acid to oxidize 

the solubilized organic and inorganic selenium without losses due to volatilization. Reaction of the sample with 

sodium borohydride released hydrides that were analyzed using an atomic absorption spectrophotometer. 

2.2.5 Elutriate/suspended particulate phase sample preparation 

Bayou Casotte water, as site water, was used in the preparation of all chemical elutriates and formed the basis 

of all suspended particulate phase (SPP) sample preparations. Water from the ODMDS was used for all SPP 

dilutions and bioassay laboratory control water was obtained from the Hampton Estuary, NH. 

Each elutriate/SPP batch was prepared by adding the homogenized soil/sediment to the site water (i.e., Bayou 

Casotte water) in a 1:4 volumetric ratio, stirring the mixture for 30 minutes, and then allowing the mixture to 

settle for 1 hour. The stirring speed was carefully set to allow mixing without cavitation. The mixture was also 

stirred manually at approximately ten-minute intervals during the mixing period. The supernatant was 

siphoned off using Teflon tubing and centrifuged prior to chemical and biological evaluations. All samples 

were stored at 4°C when not in use. The portion used for SPP bioassay test was chilled and used within 24 

hours of preparation. Related SPP toxicity dilutions series were prepared using water from the ODMDS. 

Elutriate samples were containerized for chemistry analysis and sent via overnight delivery to the chemistry 

laboratory. Samples collected for metals analysis were additionally split and filtered (using a 0.45 μm 

membrane) at the chemistry laboratory prior to analyses to obtain total and dissolved metal fractions as 

needed. 

Water column bioassays were conducted in accordance with EPA/USACE guidance for the South Atlantic 

Division (USACE/EPA, 1993), the Inland Testing Manual (EPA/USACE, 1998) and the project QAPP (ENSR, 

2005). Test organisms for the water column bioassays included mysid shrimp (A. bahia), silverside minnow 

(Menidia beryllina), and sea urchin embryos (Arbacia punctulata). 

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2.2.6 Tissue sample preparation 

A 28-day solid phase/bioaccumulation evaluation was conducted in accordance with EPA/USACE guidance 

for the South Atlantic Division (USACE/EPA, 1993), the Inland Testing Manual (EPA/USACE, 1998) and the 

project QAPP (ENSR, 2005). Testing was conducted with the bivalve (Macoma nasuta) and the burrowing 

polychaete (Nereis virens). 

At the end of the 28-day bioaccumulation assay exposure period and the 24 hour depuration period, the test 

organisms (M. nasuta and N. virens) were recovered, rinsed with clean seawater, frozen in clean glass 

containers and shipped on dry ice via overnight courier to the chemistry laboratory for preparation and 

analysis. 

2.3 Data analysis 

The array of chemical, physical and biological testing that was performed on the CLLNG soils/sediments 

provides a comprehensive data set from which material quality and its suitability for unconfined placement at 

the ODMDS can be assessed. These data sets were evaluated in the following ways: 

• Biological testing data were compared using Analysis of Variance (ANOVA) and t-tests to indicate 

those cases where site mortality results were significantly higher than reference or control values; 

• Elutriate chemistry data were compared to Federal and State water quality criteria/standards 

(WQC/WQS); 

• SPP toxicity results were also modeled using STFATE to examine water column effects relative to 

0.01 of the potential median lethal (LC50) or effects-based (EC50) values where applicable; 

• Bulk soil/sediment chemistry data were compared to reference locations, screening levels and 

historical datasets using descriptive statistics and graphical methods; 

• Biota to Sediment Accumulation Factors (BSAFs) were calculated; 

• Tissue chemistry results were compared to U.S. Food and Drug Administration (FDA) action levels 

using confidence-interval testing; and 

• Tissue chemistry results were compared to the reference site tissue chemistry using non-parametric 

and t-tests. 

A description of these evaluation methods is provided below. 

2.3.1 Sediment screening levels 

Sediment quality investigators often use sediment-screening thresholds or benchmarks in the assessment of 

sediments to examine potential risk to sediment-associated receptors. Several authors have described the 

use of biological effect threshold values (Carr et al., 1996; Long et al., 1998a and 1998b), such as Effects 

Range-Low (ERL), Effects Range-Median (ERM), and other thresholds developed from a large database of 

bioassay, benthic ecological, and microtoxicity results. Buchman (1999) provides a summary of these 

biological thresholds. Table 2-2 summarizes the available ERL and ERM screening values against which 

CLLNG soils/sediments have been compared. Effects Range-Low quotients (ERLQs) have been calculated 

when CLLNG soils/sediments exceed the screening thresholds so that readers can quickly assess the level of 

threshold exceedences. ERLQs were calculated as follows: 

ERLQ = Cc/ERL 

Cc = CLLNG concentration that exceeds ERL 

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2.3.2 Sediment reference comparisons 

Dredged material comparisons to reference sites form the basis for open water placement suitability decisionmaking. Since soil/sediment contaminant levels can vary naturally as a function of basic mineralogy, the 

metals data were first normalized to total Al. Aluminum covaries with clay mineralogy and so was used to treat 

the soil/sediment metals data. Although organic compounds generally correlate with total organic carbon 

(TOC), no relationship was found in this case, so organics data were not normalized to TOC. 

For the purposes of chemical comparisons, station-to-reference (or ratio-to-reference when normalized to Al) 

values have been calculated and presented graphically. In this way, the magnitude of station-to-reference 

differences can be more easily identified. It must be emphasized however, that the chemical observations 

were not replicated sufficiently to provide ANOVA statistical testing, since the cost to obtain and analyze 

several replicate samples per site would have been prohibitively expensive. However, these station-toreference results can be used in conjunction with the other findings to add to the weight-of-evidence in support 

of overall conclusions. 

2.3.3 Toxicity bioassay statistics 

Survival and effects data were analyzed using statistical software to determine significant differences between 

the project soils/sediments and the laboratory control, and between project soils/sediments and the agency 

selected reference site in Grand Bay. Survival data were evaluated to determine homogeneity of sample 

variances and normality of distribution using appropriate statistics. Data sets were subsequently evaluated 

using the appropriate parametric or non-parametric Analysis of Variance (ANOVA) statistic. Pair-wise 

comparisons were based on the appropriate statistical analysis presented in the EPA decision tree guidelines 

specified in individual test methods. Statistical difference was evaluated at α=0.05. For the SPP testing, acute 

exposure endpoints, LC50 and EC50 values were calculated and survival in the undiluted SPP solution was 

evaluated against the survival in the reference site diluent. Statistics were not calculated when the survival in 

the project sample was equal to or greater than survival experienced in the reference sample. 

2.3.4 STFATE modeling 

The short-term fate of dredged material placement in open water following instantaneous discharge was 

modeled using STFATE, a module of the Automated Dredging and Disposal Alternatives Management System 

(ADDAMS) described and recommended for use by the Green Book and the Inland Testing Manual 

(EPA/USACE, 1991; EPA/USACE, 1998). 

Model input data characterizing the disposal were assumed based on likely equipment and operations to be 

employed. Disposal was assumed to occur from a split-hull barge. Four scenarios were modeled: one without 

overflow of the barge as it is loaded and one allowing for overflow, each for a 3,000 cubic yard (cy) barge and 

a 5,000 cy barge. Model input parameters are summarized in Table 2-3. 

Standard model input parameters and those specific to the disposal site were provided by EPA Region 4 for 

Zone B of the Pascagoula ODMDS (Attachment 2). Model input characterizing sediment solids fraction was 

derived from the grain size data collected at SC123, the station representing the “worst case scenario” for toxic 

effects, as described in Section 4. Percent volumetric solids content for the two scenarios was assumed 

based on conversations with personnel at USACE’s Engineering Research and Development Center (ERDC) 

and engineering judgment. 

The STFATE model is generally run for two scenarios: toxicity and elutriate chemistry. The toxicity scenario is 

run if an LC50 or EC50 is calculated. Calculation of LC50 and EC50 values is described above. The elutriate 

chemistry scenario is run if the dilution required to meet Federal and State WQC (dilution factor) is 

substantially greater than 0. The dilution factor was calculated for each analyte as follows: 

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 Dilution Factor = (M – W)/(W – R) 

 M = Maximum elutriate concentration across stations 

 W = WQC (the more stringent between Federal and State) 

 R = Elutriate concentration at reference station 

Under typical tiered dredged material evaluations, bulk sediment is input as a gross approximation of the 

chemical impacts as they relate to Federal and State WQC. If criteria are exceeded, then a more refined 

approach may be undertaken by replacing bulk sediment data with actual chemical elutriate results. For the 

purposes of this study, elutriate results were obtained from the outset and so only this refined data set has 

been used as the best approximation of water column conditions relative to the relevant WQC. 

Because the dilution required to meet WQC was lower than that required for the bioassay SPP results, 

STFATE was only run for the bioassay SPP results. The most conservative test (i.e., the one that produced 

the lowest EC50 or LC50) was used. In this case, the most conservative test was the Arbacia punctulata embryo 

development test. The lowest EC50 was 50.8% (SC123). Thus, the STFATE model was run on this worst 

case scenario. 

Suitability decisions are based upon limiting permissible concentration (LPC) thresholds, which must not be 

exceeded at the ODMDS boundary at any time, and must be within acceptable levels within ODMDS four 

hours after the discharge. Project results have been presented relative to these limits. 

2.3.5 BSAF calculations 

BSAFs are defined by EPA (1995) as: 

The ratio of a substance’s lipid-normalized concentration in tissue of an aquatic organism to its organic 

carbon-normalized concentration in surface sediment, in situations where the ratio does not change 

substantially over time, both the organism and its food are exposed and the surface sediment is 

representative of average surface sediment in the vicinity of the organism. 

This definition was used in the formulation/calculation of BSAFs which may be represented by the following: 

BSAF = (Ct/L)/(Cs/TOC) 

Ct = Contaminant concentration in the tissue matrix 

L = Lipid content of the organism in percent 

Cs = Contaminant concentration in the sediment matrix 

TOC = Sediment total organic carbon 

2.3.6 Bioaccumulative tissue statistics 

Tissue chemistry results that were below FDA action levels (ALs) were further evaluated relative to the ALs by 

calculating an upper confidence limit (UCL) at the 95% confidence level. 95% UCL concentrations were 

calculated using USEPA’s ProUCL Version 3.0 software (Singh et al., 2004) 

Pair-wise comparison analysis based on the t-test was used to statistically evaluate tissue differences relative 

to the reference site after assessing normality of the datasets. Variances were assumed to be heterogeneous, 

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and the t-test for heterogeneous variance was used. The Shapiro-Wilks test was used to test the data groups 

for normality. When the raw datasets were not normally distributed, the log-transformed data were tested for 

normality. In cases when the raw data were not normal but the log-transformed data were normal, t-tests were 

run on the log-transformed data. When neither the raw data nor the log-transformed data were normally 

distributed, the Wilcoxan Rank Sum non-parametric test was used. In cases where less than 50% of the 

replicate data were detected values, the data were not compared statistically. Instead, the greatest detected 

values in the two datasets were qualitatively compared. When 50-80% of the replicate data were detected 

values, the two datasets were compared using the Wilcoxan Rank Sum test. 

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Table 2-1 Collection dates and testing specifications for soil / sediment samples (page 1 of 2) 

Sample ID Date 

 Physical Tests  Metals  Non-Metals, Non-Organics  PAHs, TPH, TOC  PCB Congeners, Nutrients  Pesticides, PCB Aroclors  VOCs 

PHASE 11 

Sediment Grabs 

Grand Bay Reference 5-Dec-05 x x x x x x x 

Soil Cores 

SB1U1 5-Dec-05 x x x x x x x 

SB1L1 5-Dec-05 x x x x x x x 

SB2U1 5-Dec-05 x x x x x x x 

SB2L1 5-Dec-05 x x x x x x x 

SB3U1 4-Dec-05 x x x x x x x 

SB3L1 4-Dec-05 x x x x x x x 

SB4U1 2-Dec-05 x x x x x x x 

SB4L1 2-Dec-05 x x x x x x x 

SB5U1 2-Dec-05 x x x x x x x 

SB5L1 2-Dec-05 x x x x x x x 

SB6U1 1-Dec-05 x x x x x x x 

SB6L1 1-Dec-05 x x x x x x x 

SB7U1 6-Dec-05 x x x x x x x 

SB7L1 6-Dec-05 x x x x x x x 

SB8U1 2-Dec-05 x x x x x x x 

SB8L1 2-Dec-05 x x x x x x x 

SB9U1 1-Dec-05 x x x x x x x 

SB9L1 1-Dec-05 x x x x x x x 

SB10U1 3-Dec-05 x x x x x x x 

SB10L1 3-Dec-05 x x x x x x x 

SB11U1 3-Dec-05 x x x x x x x 

SB11L1 3-Dec-05 x x x x x x x 

SB12U1 30-Nov-05 x x x x x x x 

SB12L1 30-Nov-05 x x x x x x x 

Sediment Cores 

SC1 3-Dec-05 x x x x x x x 

SC2 3-Dec-05 x x x x x x x 

SC3 3-Dec-05 x x x x x x x 

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Table 2-1 Collection dates and testing specifications for soil (SB) and sediment (SC) samples 

(page 2 of 2) 

Sample ID Date 

 Physical Tests  Metals  Non-Metals, Non-Organics  PAHs, TPH, TOC  PCB Congeners, Nutrients  Pesticides, PCB Aroclors  VOCs  SPP Bioassay  10-d Sediment Bioassay  28-d Bioaccumulation  Elutriate Chemistry 

PHASE 2 

Sediment Grabs 

Grand Bay Reference 5-Dec-05 Analyses conducted in Phase 1 x x 

Grand Bay Reference (resample)2 21-Mar-06 x x x x x x x 

Soil Cores 

SB7L2 6-Dec-05 x x x x x x x x x x 

SB10L2 3-Dec-05 x x x x x x x x x x 

SB12L2 30-Nov-05 x x x x x x x x x x 

Sampling Pits 

SB4U2 19-Dec-05 x x x x x x x x x x 

SB7U2 20-Dec-05 x x x x x x x x x x 

SB9U2 19-Dec-05 x x x x x x x x x x 

SB10U2 20-Dec-05 x x x x x x x x x x 

SB11U2 20-Dec-05 x x x x x x x x x x 

SB12U2 19-Dec-05 x x x x x x x x x x 

SB1U2 20-Dec-05 Analysis of composite only 

SB2U2 20-Dec-05 Analysis of composite only 

SB3U2 20-Dec-05 Analysis of composite only 

SB5U2 19-Dec-05 Analysis of composite only 

SB6U2 19-Dec-05 Analysis of composite only 

SB8U2 19-Dec-05 Analysis of composite only 

Composites3 

C1U2 (SB1U2,SB2U2,SB3U2) N/A x x x x x x x x x x 

C2U2 (SB5U2,SB6U2,SB8U2) N/A x x x x x x x x x x 

C3L2 

(SB1L1,SB2L1,SB3L1,SB4L1) N/A x x x x x x x x x x 

C4L2 

(SB5L1,SB6L1,SB8L1,SB9L1,SB

11L1) NA x x x x x x x x x x 

SC123 (SC1,SC2,SC3) NA x x x x x x x x x x 

1

 Phase 1 testing was conducted to aid subsequent composite decision-making. All Phase 2 test 

parameters were measured on the same sample homogenate. 

2 10-d sediment bioassay testing consisted of second round of Leptocheirus plumulosus testing only. 3 Composite makeup; e.g. SB1L, SB2L, SB3L and SB4L were pooled together to form a single composite. 

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Table 2-2 Available Sediment Screening ERL and ERM Levels (from Buchman, 1999) 

Parameter Units1 ERL ERM 

Arsenic mg/kg 8.2 70 

Cadmium mg/kg 1.2 9.6 

Chromium mg/kg 81 370 

Copper mg/kg 34 270 

Lead mg/kg 46.7 218 

Mercury mg/kg 0.15 0.71 

Nickel mg/kg 20.9 51.6 

Silver mg/kg 1 3.7 

Zinc mg/kg 150 410 

2-Methylnaphthalene ug/kg 70 670 

Acenaphthene ug/kg 16 500 

Acenaphthylene ug/kg 44 640 

Anthracene ug/kg 85 1100 

Benzo(a)anthracene ug/kg 261 1600 

Benzo(a)pyrene ug/kg 430 1600 

Chrysene ug/kg 384 2800 

Dibenzo(a,h)anthracene ug/kg 63 260 

Fluoranthene ug/kg 600 5100 

Naphthalene ug/kg 160 2100 

Phenanthrene ug/kg 240 1500 

Pyrene ug/kg 665 2600 

Total PCBs ug/kg 22.7 180 

4,4'-DDD ug/kg 2 20 

4,4'-DDE ug/kg 2.2 27 

4,4'-DDT ug/kg 1 7 

Alpha-Chlordane ug/kg 0.5 6 

Dieldrin ug/kg 0.02 8 

Gamma-BHC (lindane) ug/kg - 0.992

1

 All values are represented in dry wt units. 

2

 Probable Effect Level. 

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Table 2-3 STFATE Model Input Parameters for Disposal in Zone B of the Pascagoula ODMDS 

Input Parameter Units Value(s) 

Current Velocity ft/s 0.328 at 5 ft depth 

0.164 at 40 ft depth 

Duration of Simulation Sec 14,400 

Vessel Capacity yd3 3000, 5000 

Vessel Speed ft/s 0 

Pre- and Post- Dump Draft ft 20/4 

Size of Vessel L (ft) x W (ft) 250 x 55 

Time to Empty Vessel Sec 25 

No overflow Overflow 

Volumetric % Solids1 Volume of total barge 

volume (%) 

50 65 

Sediment Fraction Sand 

Silt 

Clay 

Clumps (assume 25%)1

0.199 

0.098 

0.079 

0.125 

0.258 

0.127 

0.102 

0.163 

Density of Site Dredging Water g/cm3 1.02 

(average of surface and 

bottom water density at 

ODMDS) 

Chemical Elutriate Simulation Input 

Contaminant in Material mg/L N/A2

Background Concentration mg/L N/A2

WQC Standard mg/L N/A2

SPP Bioassay Toxicity Test Input 

Most Sensitive Organism Arbacia punctulata 

embryo development 

Sample/Composite with greatest impact SC123 

LC50/EC50value EC50 – 50.8% 

Limiting Permissible Concentration 0.508% 

1

Assumed based on discussions with ERDC.

2

Dilution required to meet WQC is less than that required for the bioassay SPP 

result. 

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Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Appendix E-1 page 29 

Figure 2-1 Proposed and Actual Soil and Sediment Sampling 

Locations Slip Area MPRSA/CWA Characterization

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Appendix E-1 page 30 

Figure 2-2 Reference Sedimentation Station

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Appendix E-1 page 31 

Figure 2-3 Inshore and Offshore Water Sample Locations

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
3.0 Project field effort 

This section provides a chronology of field events, final station position information, and difficulties 

encountered during the effort. Project soil sampling commenced November 30, 2005, and the site 

soil/sediment sampling objectives were completed in December 2005. Water-related sampling was performed 

in subsequent months and another reference sediment sampling was amended to the program and collected 

on March 21, 2006, to complete the field program. Table 3-1 provides a summary and chronology of the field 

activities. 

3.1 Mobilization and navigation 

Several field teams were mobilized during the performance of the field program as listed below: 

• Boart Longyear (Huntsville, AL) performed rotosonic soil collection; 

• Mullins Construction Co. (Pascagoula, MS) conducted the track hoe excavations; 

• Walters Marine (Pascagoula, MS) provided waterfront equipment and services (tug, spud barge and 

crane operations); and 

• Brunswick Pilots (Brunswick, GA) provided vessel support for coastal and offshore water and 

sediment collections. 

• Alpine Ocean Seismic Survey (Norwood, NJ) provided vibracoring services. 

Sampling positions in upland areas were flagged for easy site recognition. Coastal locations were marked with 

a small surface float to assist the crane operator with vibracore frame positioning. Offshore positioning was 

accomplished using DGPS instrumentation as described in Section 2. Table 3-2 summarizes the actual station 

positions achieved. 

Field observations including material recovery, visual descriptions, and penetration depth were documented on 

field logs and are provided in Appendix A. 

3.2 Sample transfers 

The analytical project team included four laboratories: 

• Envirosystems, Inc (ESI; Hampton, NH) provided core processing facilities and performed bulk 

sediment, suspended particulate phase, and bioaccumulation bioassays; 

• WestonSolutions, Inc. (Port Gamble, WA) performed specialized bulk sediment toxicity bioassays; 

• GeoTesting Express (Boxborough, MA) provided physical testing services; and 

• Columbia Analytical Services (Kelso, WA) provided chemical testing services. 

Background samples for chemical or physical testing were transferred directly from the field to the associated 

laboratory. All other samples (as intact cores, bulk excavation material, sediment or water grab samples) were 

transferred to the processing facility (ESI) for further processing before subsequent testing commenced. All 

field to lab and inter-lab transfers were conducted under chain-of-custody procedures as specified in the 

project QAPP. These records are included in the laboratory backup appendices. 

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3.3 SAP deviations and difficulties encountered 

Difficulties encountered during the field effort generally related to station access or sediment recovery. Several 

stations were moved to allow access by the drilling support truck or to avoid site obstructions, although soils 

and sediments were generally collected within 100 feet of the target sampling locations. Final sampling 

positions are depicted in Figure 2-1. 

Soil cores associated with stations SB1, SB8, SB9 and SB12 were repositioned more than 100 feet from the 

original target location. Station SB1 was shifted to the northeast because the proposed location was not 

accessible by the support truck. Station SB8 was also relocated in order to avoid a former building slab and 

foundation. Stations SB9 and SB12 were repositioned to the northeast and southeast, respectively, in order to 

avoid other obstacles. 

Sediment cores labeled SC1 and SC2 were collected in close proximity to original target positions, however, 

coastal station SC3 was repositioning due to shallow water restrictions. All soil and sediment cores reached 

the project depth of 46 feet below MLLW with the exception of core SC1, which reached only 38 feet below 

MLLW. However, this does not critically affect the suitability evaluation of this coastal area since the area has 

been evaluated as a single unit (SC1, SC2, and SC3 composite). As an added note, soil cores at stations SB7 

and SB10 were collected from sidewall locations with location-specific project depths of 26 feet and 12 feet 

below MLLW, respectively. Figure 3-1 depicts the penetration depth achieved at each site sampling station. 

Initially coring methods were expected to obtain sufficient material from upper and lower site strata to meet all 

project needs. However, the upper sand horizon was thinner than expected and so an excavation approach 

was mobilized within a few weeks of the coring effort to obtain the needed sample volumes. A standard track 

hoe was used for most excavations but because three of the stations (SB1, SB10, and SB11) were in 

wetlands, a track hoe with an extended arm, capable of reaching ca. 30 to 35 feet was mobilized. 

In some cases excavations required further repositioning (versus cored positions) to avoid sampling 

constraints. Sampling pit SB9 was positioned about 120 feet to the northeast and sampling pit SB2 was 

relocated a short distance to the east. Sampling pit SB11 was also moved to the northwest to an area that 

contained less standing water. 

During excavation of the sampling pits, the water table at station SB4 was within the upper sand layer creating 

a slurry when supporting sidewall material was removed. Recovery was therefore very poor at the sand/clay 

interface, creating a gap in the soil column at this station (Figure 3-1). A similar gap (of about four feet) was 

not collected during excavation activities at station SB3 because of track hoe arm (reach) limitations. An 

apparent gap of 1-2 feet is also depicted at a few other locations (Figure 3-1), but is likely related to 

topographic variability of the interface at these stations since some offset occurred between coring versus 

sampling pit positioning. 

No difficulties were encountered during reference site or water column sampling efforts. 

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Figure 3-1 Sampling pit and soil/sediment core collection intervals, with fill layers

Elevation SB1 SB2 SB3 SB4 SB5 SB6 SB7 SB8 SB9 SB10 SB11 SB12 SC1 

(ft MLLW) 

Fill (as determined from sampling pits)Upper layer sample (collected from sampling pits)Lower layer sample (collected from cores)

16141210

86420

-2-4-6-8

-10-12-14-26-28-30-16-18-20-22-24-58-60-48-50-52-54-40-42-56-44-46-32-34-36-38

Project Depth (-46 MLLW)

Sidewall Locations

No fill No fill

Fill

UpperLower

Sedimas wh

SC1 - 90% recove

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4.0 Results and discussion 

To evaluate suitability, the site to be dredged was divided into upper and lower sampling units based on site 

stratigraphy. The surface fill from these sites was not included in this evaluation because it will be re-used for 

onsite construction and not removed for offsite placement. Suitability discussions focus on the upper sand 

layer (immediately below the surface fill), the lower clay-rich sediment (beneath the sand horizon), and the 

coastal sediment section. The lower clay-rich layer could be subdivided further, because a deeper 

interbedded sand and clay exists below the thick clay-rich layer, but for the purposes of this evaluation, a 2-

layer model is sufficient. 

Selected individual stations were pooled together to form an area-wide composite while other stations were 

evaluated individually. Cores collected in the coastal area were pooled together from the start. The final 

sample pooling recommendations provided by CE SAM and EPA are summarized in Table 4-1. 

The dredged material testing program proceeded in two phases. Phase 1 rapid chemistry and grain size 

analyses were conducted to support sample pooling decisions and maximize full scale testing efficiency. 

These data are included here to incorporate the only VOC measurements made in this program and provide a 

complete record of the project data (Table 4-2). Physical and chemical analyses were later repeated during 

Phase 2 of the testing program so that all chemical, physical, and biological testing could be performed on the 

same sample homogenate. It is the Phase 2 dataset that forms the basis of the suitability decision-making, 

therefore, subsequent discussions focus primarily on the Phase 2 dataset. 

The following sections present results from the three potential exposure pathways evaluated under the 

MPRSA; bulk sediment quality, water column impacts, and bioaccumulative potential of the site material. 

4.1 Sediment physical, chemical and toxicity characteristics 

Bulk sediment quality and character are based on physical, chemical and toxicity bioassay tests. A wide range 

of chemical parameters was examined (Table 4-2) and toxicity was determined using 10-day exposures to 

crustaceans and amphipods. The following sections present these findings; full laboratory backup files are 

provided in Appendices B, C and D. 

4.1.1 Sediment texture 

Two primary sediment characteristics are sediment grain size and organic carbon content. Understanding 

sediment particle sizes and corresponding mineralogy is critical for evaluating sediment chemistry because 

chemical components vary naturally based on the mineralogy present. For example, the metal concentrations 

associated with quartz sand are naturally much lower than those associated with fine-grained aluminosilicates 

(clay minerals). For this reason, direct site-to-reference comparisons are most useful if data are first 

normalized to aluminum. Similarly, total organic carbon (TOC) is another primary sediment characteristic. 

Chemical affinity to naturally occurring organic compounds, and chemical enrichment within biogenic carbon 

material are important processes that result in chemical enrichment within sedimentary organic carbon. For 

this reason, TOC is often used to normalize chemical parameters, particularly organic compounds. Both TOC 

and corresponding organic chemical concentrations were generally very low at the project site and so TOC 

normalization was not necessary. 

Figure 4-1 summarizes the sediment textures observed at the site. The site is characterized by a sand-rich 

upper layer, underlain by material that contains greater amounts of clay. Samples collected from the upper 

layer typically contained more than 70% sand and only 5-15% clay. Samples collected from the lower 

sediment layer were generally more than 50 percent silt and clay, particularly in side-wall areas (SB7 and 

SB10), where project-required collection depths were relatively shallow, and deeper sand horizons were not 

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penetrated. One minor deviation to this trend occurred at station SB12, where the upper material contained a 

greater fraction of silt (ca. 50%). Overall, the coarse grained nature of the surface layer prevailed and 

corresponding chemical signatures were lowest across the entire site in this upper sand layer, as further 

detailed in the following section. 

The coastal cores were pooled to form a single horizontal and vertical (surface to maximum depth) composite. 

On a tertiary diagram (Figure 4-1), the composite grain size results plot between the coarse grained upper and 

fine grained lower site stations. The Grand Bay reference site is similar to SB12 in that it contains a high 

percentage of silt (51%). Grain size curves for all samples are provided in Appendix B. 

TOC measurements are critical for geochemical evaluations because of the chemical enrichments that occur 

in carbon-rich horizons. The findings from station SB4UU analyzed during Phase 1 of the testing program 

illustrate this fact. During the initial core processing exercises, the field team noted that the uppermost portion 

of material at station SB4 was moist, gray to brown material containing peat. It was this unique organic-rich 

feature that prompted the field team to segment this station during Phase 1 subsampling, breaking the upper 

layer into two sampling units. The uppermost peat-rich layer was labeled SB4UU, and the more common 

sand-rich horizon was labeled SB4U. When analyzed, this brownish peat-rich material from station SB4UU 

contained some of the highest metal concentrations for the site. 

Nonetheless, TOC is relatively unimportant throughout the site as a determinant of sediment chemistry 

because carbon concentrations were very low with the exception of station SB4UU. This was particularly true 

in the upper sand layer where concentrations ranged from 0.04 to 0.24% (Tables 4-2 and 4-3). Lower layer 

TOC measurements were in the 0.33 to 1.21% range and coastal values, including the reference site, were 

measured in the range of 0.34 to 1.37%. 

Detailed physical and chemical sediment measurements are provided in Table 4-2 (Phase 1) and Table 4-3 

(Phase 2). In cases where values were quantified between the laboratory method detection limit (MDL) and 

the reporting limit (RL), the result is considered an estimate and qualified with a “J” in the data table. In cases 

where analyte signals were not detected, the RL value with an accompanying "U" qualifier has been provided. 

Unless otherwise noted, nondetected results were censored to maximize data usage for subsequent graphical 

data comparisons to either reference sites or screening values. In these cases, the nondetected result was 

replaced with one-half the RL. This censoring method is considered appropriate to match the existing data 

structure since the reported J-qualified data were generally a small fraction of the RL. 

4.1.2 Sediment chemistry 

After basic sediment properties like grain size and TOC content are understood, the chemical properties can 

be evaluated. As expected, clay-rich station samples, like SB7L and SB10L are generally enriched with 

metals relative to sandy sediment samples. Further, station SB4UU, unique in its elevated TOC content 

relative to the other stations, contains the highest concentration of As and Hg. 

One way to address this natural co-variation between sediment properties and sediment chemistry is to 

normalize the results before making reference comparisons. For metals, this is typically done using Al data as 

a surrogate for aluminosilicate (clay) minerals. The validity of this process is underscored by the high degree 

of correlation observed between individual metals and Al. Table 4-4 lists metal correlation coefficients and 

Figure 4-2 provides example plots. 

Under some circumstances, organic chemical data can be normalized to TOC measurements to factor out 

carbon enrichment phenomenon as discussed earlier. However, in this case sedimentary carbon is generally 

very low in the project samples and there is no apparent correlation (e.g., r2

=0.006 and r2=0.05 for Phase 1 

and Phase 2 Total PAHs) so TOC normalization was not performed. 

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There are several ways to evaluate the environmental significance of sediment-bound contaminants, and the 

following are incorporated in this assessment: 

1) Reference comparisons 

2) Regional comparisons 

3) Biological thresholds 

4) Bioavailablilty considerations 

Site to reference comparisons. To aid in station-to-reference comparisons, ratios have been calculated and 

presented graphically in figures 4-3, 4-4, and 4-5. For calculation purposes, when neither station nor reference 

values were detected, the ratio was assigned a value of one. PCBs and pesticides were not generally 

detected and so were not included in this assessment. 

These data illustrate that in most cases, site concentrations were lower than reference site concentrations (i.e., 

most values were <1.0). The most prominent deviation is apparent at station SB7U, where total PAHs and Ag 

exceed concentrations at the reference site. Again sedimentary Ag was normalized using Al for the site and 

reference station samples. Apparent Sb and Se differences that are noted between site SB11 and the 

reference site are in fact related to using reporting limits in the calculation. These metals were not detected in 

the site sample, but small amounts were detected at the reference site and so a large difference was 

calculated using 1⁄2 the corresponding reporting limits. 

Regional comparisons. Historic regional datasets provide an excellent means for placing localized sediment 

chemical observations within a regional context. For this purpose, Casotte Landing slip area sediment data 

(CLLNG data) have been compared to NOAA’s National Status and Trends (NS&T) data for four sediment 

monitoring sites in the vicinity of the Casotte Landing project area (Table 4-5, Figure 4-6). Data from 1984 to 

1990, the most recent monitoring years available, were used for the comparison. 

For consistency across datasets, non-detect values were replaced with "0" since NS&T data used this 

approach. NS&T data were averaged across sampling years for each station. Because replicate information 

is limited for many of these datasets, rigorous statistical comparisons were not undertaken. Rather, 

descriptive statistics have been generated and form the basis of these comparisons. To further improve the 

comparability of the datasets, metals data have been normalized to Al in an attempt to minimize apparent bias 

resulting from natural changes in mineralogy. Organics data were not normalized to TOC because there was 

no correlation between organics and TOC for the CLLNG data, as described above. 

Metals concentrations in the Casotte Landing dataset were generally comparable to the NS&T dataset, 

indicating that dramatic changes in sediment metal chemistry have not occurred since the earlier study 

(Figure 4-7). In fact, metals concentrations were generally lower in slip area sediments than in NS&T 

sediments. 

PAH, PCB, and pesticide comparisons are provided in Figure 4-8. PAH concentrations were generally lower 

in the Casotte Landing slip sediments than in the NS&T sediments, although variability was high within each 

dataset. PCBs and pesticides were generally not detected in the CLLNG sediments, and when they were 

detected, they were at lower concentrations than in the NS&T site sediments. 

Biological effect benchmarks. Reference or regional sediment data comparisons provide an excellent way 

to identify contaminants that are elevated above regional or background concentrations, but the environmental 

significance of such elevated concentrations requires further assessment. One way to evaluate this 

significance is to compare site data to biological effect benchmarks such as Effect Range Low (ERL) or Effect 

Range Median (ERM) thresholds established for this purpose (e.g., Buchman, 1999). ERL and ERM values 

are provided in Table 2-2. In relation to these benchmarks, only a few CLLNG project samples exceed the 

lowest (ERL) threshold and these exceedances are minor. Arsenic and Hg contained in the sediment 

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collected from station SB4UU each exceeded corresponding ERL values by a factor of 1.1. Acenaphthene 

measured in the material collected from station SB7U exceeded the corresponding ERL by a factor of 1.6. 

None of the samples analyzed during the Phase 2 testing program exceeded even the lowest (ERL) 

benchmark. 

Overall, while selected parameters were measured above reference or background concentration levels, these 

concentrations are still very low relative to biological effect benchmarks. The few values that exceed ERL 

thresholds are printed in boldface in Table 4-2. Corresponding quotients (ERLQ), derived by dividing the 

sediment chemical concentration by the corresponding chemical ERL value, are indicated in parentheses 

following the exceeded ERL result. 

Contaminant bioavailability. When assessing sediment quality, the bioaccumulative potential of sediment 

contaminants is another important consideration. The most rigorous way to address bioaccumulation is to 

perform bioaccumulation bioassays as was done during this study. These findings are discussed in a later 

section. 

In the case of metal contaminants, the relationship between sedimentary sulfides and sulfide-forming heavy 

metals provides information for making bioavailability predictions. If available sulfide concentrations are 

sufficiently high relative to the available metal concentrations, then very insoluble metal sulfides will precipitate 

from solution, effectively immobilizing the metals and rendering them unavailable to the resident biology. 

While this is a simpler approach than bioaccumulation studies, these measurements were made during the 

testing program as another line of investigation and so related data are presented in this section. 

To evaluate the sedimentary sulfide to metal relationship, the ratio of the sum of simultaneously extracted 

metals (Cd, Cu, Pb, Hg, Ni and Zn) to acid volatile sulfide (SEM/AVS) has been calculated and provided in 

Tables 4-2 and 4-3. Available sulfide was not detected in most CLLNG samples and so existing SEM metals 

could potentially be available for biological uptake. Only CLLNG stations SC123 (coastal cores), SB3U, SB3L, 

SB6L, SB7L and the reference site contained measurable AVS concentrations. However, results from this 

simplified approach are of less diagnostic value than the actual bioaccumulation tissue chemistry results and 

associated biota to sediment accumulation factors presented in subsequent sections. 

4.1.3 Whole sediment toxicity 

Bulk sediment bioassays are an important part of the overall suitability testing framework for ODMDS 

consideration and agency guidance specifies that a filter feeder, a deposit feeder, and a burrowing organism 

be represented in the assay. The crustacean Americamysis bahia and the crustacean amphipod Leptocheirus 

plumulosus were selected in this study to represent these feeding strategies. A. bahia is a filter and deposit 

feeder that spends much of its time in the water above the sediment-water interface. The amphipod L. 

plumulosus is a burrowing filter and deposit feeder that builds and lives in a tube-like structure within the 

sediment. 

The amphipod is particularly useful for evaluating the potential effects on organisms living and feeding within 

the sediment matrix given its burrowing and deposit feeding habits. However, there are some benthic habitats 

(i.e. sediment types) that are not hospitable to amphipods. For example, amphipods are unable to burrow and 

build tube structures within sediment with a texture at either end of the grainsize spectrum. In fact, 

experiments conducted at ERDC have identified adverse amphipod effects when placed in sediments of this 

nature (T. Bridges, pers. comm). 

Casotte Landing test materials are unique in that a thick layer of dense, clay-rich sediment is present below a 

compacted sand layer. Furthermore, much of the material is carbon-poor (low TOC), is deeply buried, and has 

been separated from the marine environment for a very long time. These are important characteristics 

because it has been demonstrated that an established marine microbial assemblage and sufficient organic 

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carbon as a food source are essential when conducting toxicity bioassays. If these conditions are not met, 

then spurious test organism mortality can occur (Word et al., 2005). 

Casotte Landing material therefore required additional sediment bioassay testing to evaluate the potential 

effects of the sediment texture and the sterile, nutrient-poor nature of the sediments. As a starting point, the 

standard toxicity bioassays were conducted with the shrimp and amphipod using standard handling 

procedures. Survival of the shrimp was very good in all samples but, as expected, higher than normal 

mortality was observed in many of the amphipod tests. An experimental framework was next developed in 

consultation with CE SAM and EPA to evaluate the sediment sterility and lack of an adequate carbon food 

source (Attachment 1). A complicating factor was identified in that amphipods exposed to the reference site, 

not tested since hurricane Katrina ravaged the area, also exhibited a higher than expected rate of mortality. 

The testing framework was developed to answer the following questions: 

• Although the amphipods survived very well in lab control sediments, was the batch of organisms 

compromised in some way, leading to the lower than expected observed survival, particularly in the 

Grand Bay reference sediment? 

• Would conditioning the sediments for a few weeks and allowing the marine microbes to be established 

be sufficient to enhance amphipod survival? 

• Is the (low) sediment TOC bioavailable to benthic organisms or is the lack of bioavailable TOC related 

to the observed mortality? 

To address the question of amphipod quality, the tests were re-run using archived sediment from each of the 

stations. The remaining questions have been examined by other authors. The issue of sterility due to a lack 

of marine microbial community was addressed by Word et al. (2001) in an evaluation of proposed dredged 

material from a freshwater habitat, Bahia Lagoon, adjacent to the Petaluma River, California, to a marine 

disposal site. After allowing the sediments to acclimate to marine conditions, amphipod and polychaete worm 

assays were successfully conducted and the agencies determined that the sediment was suitable for 

beneficial use in the marine environment. 

The issue of low usable TOC in sediments was addressed by Pinza, Mayhew and Word (Pinza et al 1996) 

during an evaluation of deeply buried sediment from Richmond Harbor, California as part of a dredged 

material evaluation project for the USACE San Francisco District. This project required evaluating deeply 

buried material similar to that of Casotte Landing for placement in the marine environment. Like the Casotte 

Landing material, the Richmond Harbor material contained little/no contaminants, but it was hard packed and 

contained very low TOC. Concerns were raised with the agencies about the nutrient poor nature of the 

sediments, and with agency approval, the investigators provided a minimal food source (TetraMinTM and 

Enteromorpha sp algae) to the test organisms so that chemical toxicity could be distinguished from organism 

starvation. Under these conditions, the test organisms interacted with the test sediment in a normal manner 

and survival in the test treatments increased substantially. The agencies reviewed the successful test results 

and determined that sediment from Richmond Harbor was suitable for unconfined marine placement. 

In addition, a number of standardized protocols recognize the need to meet the nutritional requirements of test 

organisms by providing a minimal food source (e.g., TetraMinTM) during the exposure period. This includes 

chronic toxicity tests with the amphipod L. plumulosus (USEPA 2001) and the polychaete, Neanthes 

arenaceodentata (Puget Sound Estuary Protocols, 1995; Bridges et al., 1997). A TOC study conducted during 

the development of the chronic L. plumulosus assay found no significant effects between TOC concentrations 

of 1% to 7%; however, below 1% TOC, significant decreases in survival, growth and reproduction were 

observed (DeWitt et al. 1997 as cited in USEPA, 2001). This is particularly relevant at Casotte Landing where 

sedimentary TOC is very limited and of questionable value to organisms. 

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To fully answer these questions as they relate to Casotte Landing sediments, the following three experimental 

treatments, modeled after the USACE Richmond Harbor and other studies, were undertaken with CE SAM 

and EPA approval: 

Treatment I – Archived site sediments and freshly collected Grand Bay reference sediment were tested with a 

new batch of test organisms. 

Treatment II – Archived site sediments were conditioned, or “acclimated” to establish a marine sediment 

microbial assemblage. In some cases, samples used for the 28-day bioaccumulation test were re-used as it 

was acknowledged that their conditioning would be complete. In other cases, untested archive sediments 

were conditioned prior to testing. For these sediments, ammonia levels were measured during the 

conditioning process to monitor microbial activity. 

Treatment III – Previously conditioned sediment was supplemented with TetraMinTM in a manner similar to the 

EPA protocol for the chronic test with the amphipod, L plumulosus (USEPA, 2001). The food ration was set at 

two feedings in 10 days to minimize the amount of food in the test system. 

For each treatment, the freshly collected reference sediment was tested, but since the reference sediment was 

taken directly from the marine environment, it was not conditioned for the tests. TetraMinTM supplements were 

added to the reference sediment in the Treatment III scenario for consistency. The tests were conducted in 

three batches, each with separate lab control samples and reference samples. 

Test Results 

The mysid shrimp survival is summarized in Table 4-6a. Tables 4-6b and 4-6c summarize the amphipod 

survival results for various treatment scenarios. Laboratory bench sheets are included in Appendix D and 

supporting statistics are summarized in Tables 4-7a and 4-7b. One lab control failure (<90% survivorship) 

occurred during the amphipod testing (batch 2) and the samples in the batch were re-tested. 

Average A. bahia survival in the Grand Bay reference site sample was 90% and survivorship in site sample 

exposures ranged from 73% to 98%. The lowest survivorship (73%) was measured for A. bahia exposed to 

SB12L2, although there was no statistical difference from the reference sample and survival in 4 out of 5 

replicates was within the same range as the reference replicates. The statistical evaluation for A. bahia is 

provided in Table 4-7a. 

L. plumulosus whole sediment assay results are summarized in Table 4-6b, which includes results for the 

original amphipod assay and the subsequent experimental assays, labeled Treatment I, II, and III. As 

discussed previously, a review of the initial test results by EPA and CE SAM identified unusually low survival 

for Grand Bay reference sediment relative to historic testing results. Therefore, a second Grand Bay reference 

sample was collected and included in the additional experimental assays. 

Treatment I results. Survival in the archived slip area station tests ranged from 8% in SC123 to 60% in 

SB10L. Survival in the archived Grand Bay reference site was only 31%, confirming that the low survival 

observed in the initial testing of this material was probably not related to the general health of the test organism 

culture. Furthermore, survival in the freshly collected Grand Bay reference sample (obtained March 2006) 

ranged from 52% to 81% in the three test batches. Because this level of mortality is uncommon for this 

reference site, hurricane Katrina or other “natural” phenomenon may have negatively altered the site. Overall, 

the results of testing with the archived site samples are generally consistent with the reduced survival 

observed in the initial L. plumulosus assay. 

Treatment II results. L. plumulosus survival in the acclimated sediment from slip area stations ranged from 

16% in SB4U to 62% in SB12U (Table 4-6b) indicating that conditioning these largely sterile deep sediments 

alone is insufficient to provide a suitable environment for the amphipods. 

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Treatment III results. Survival in the Grand Bay reference sample with the addition of food ranged from 81% 

to 87% representing a survivorship increase above the same reference sample without TetraMinTM added 

(52% to 81%). Survival in the acclimated slip area station sediments with the addition of food ranged from 

62% in C3L2 to 88% in SB7L representing a significant increase over the archived and acclimated sediments, 

implying that a lack of food is likely responsible for the observed mortality in these treatments. Furthermore, 

observations made by laboratory staff indicate that the L. plumulosus in the acclimated and fed treatments 

were actively burrowing and interacting with the sediments and surviving test organisms appeared healthier 

(e.g., better color, more active) than those observed in the un-fed treatments which were thinner and slow 

moving. 

Statistical comparisons presented in Table 4-7b indicate that four samples (C2U2, SB12U2, C3L2, and C4L2) 

prepared according to Treatment III were statistically different from the batch-specific Grand Bay reference 

sample. However, survival in all slip area stations is within 20% of the batch specific reference sample, which 

is the critical threshold for identifying acutely toxic conditions in amphipod bioassay results (EPA/USACE, 

1998). Based on these results the material is not considered toxic to marine benthic organisms. However, it is 

nutrient poor and benthic infauna would begin to colonize the surface sediment in the natural marine 

environment only after biogenic carbon accumulated at the sediment surface from the overlying water column. 

The Treatment III bioassay was considered successful for several reasons: 

• Amphipod survival was greater than 90% in the lab controls; 

• Amphipods behaved normally; they burrowed into the sediment and showed no signs of reacting to 

the sediment itself; and 

• There was no sign of food or detritus on the sediment surface, indicating that the minimal TetraMinTM 

amount provided was appropriate. 

Based on these results, and the lack of significant levels of chemical contaminants in the sediment, it is 

apparent that it was a lack of food (e.g., bioavailable organic material) in the station samples, and not chemical 

stressor(s) that caused decreased survival in the original assay. 

Ancillary test information. During the amphipod bioassay, the organisms were closely observed to ensure 

that they were interacting with the test sediment normally. Figure 4-12 shows an example of the sediment 

surface in an amphipod test chamber that received TetraMinTM. This indicates that the food ration was 

minimal and that the organisms were burrowing and behaving normally when exposed to the test material. 

Biologists at the testing laboratory also noted that surviving organisms associated with Treatment I and II were 

smaller than normal and slow moving. This “lethargic” character, as described by the testing staff, is contrary 

to normal test organism appearance, which is typically either healthy looking (normal size and active) or dead. 

It was the opinion of the testing staff that starvation would produce the lethargic characteristic and lack of 

growth. 

Ancillary data, including bioassay TOC data and the physical and chemical data associated with the Grand 

Bay reference sample collected in March 2006, are provided in Appendix E. 

Overall, the results of the whole sediment toxicity tests with A. bahia indicate that the Casotte Landing 

sediments collected are not acutely toxic relative to the associated reference sediment. On the whole, 

Treatments II and III simulate the natural sequence of events when marine sediments are disturbed or scoured 

to a depth where surface microfauna do not exist and food for benthic organisms is initially limited. During the 

natural recovery process, the typical microbial community would re-establish itself within days/weeks (as 

observed in laboratory studies; Word et. al., 2005) and, in quiescent areas, a natural accumulation of fresh 

biogenic material raining down from the overlying water column would occur. The whole sediment toxicity tests 

with L. plumulosus in Treatment III indicate that the Casotte Landing sediments are not acutely toxic, relative 

to the associated reference sediment. 

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4.2 Water column evaluations 

Water column evaluations performed in this study incorporated the analysis of chemical elutriate samples and 

suspended particulate phase bioassay tests. The full suite of chemicals were measured in the elutriate 

mixtures to evaluate possible dredged material effects on water quality at the ODMDS. Suspended particulate 

phase toxicity bioassays included three test species: crustacean, fish, and sea urchin larvae. Acute toxicity as 

well as very sensitive (larvae) developmental effects have been evaluated. 

4.2.1 Elutriate chemistry 

Table 4-8 summarizes elutriate chemistry results obtained after mixing the site materials with Bayou Casotte 

seawater to simulate dredged material mixing at the ODMDS. Evaluation of water quality parameters is an 

important part of determining whether dredged material is suitable for placement at an ODMDS and so 

maximum chemical elutriate results measured among the full station set are provided along with MS State and 

Federal Water Quality Criteria (WQC) in Table 4-9. 

Overall, the prepared elutriate seawater samples contained chemicals at concentrations that were very low 

relative to the WQC. PCBs and pesticides were not detected in any of the seawater samples. With the 

exception of naphthalene, which was measured at 0.26 ug/L in sample C2U2, all measured PAHs were either 

undetected or detected as estimates (J-qualified) below laboratory reporting limits. All measured organic 

compound concentrations (including naphthalene) where well below relevant water quality standards. 

Metals were evaluated relative to dissolved fractions, since MS State criteria are based on this aqueous 

phase. Total (dissolved + particulate) Hg was also evaluated. Most metals and non-metals/nutrients were 

also measured in elutriate seawater mixtures at concentrations below water quality standards. Exceptions 

included phosphorous, Ni, and Hg. 

Phosphorous contained in the elutriate mixture prepared from the station SB10U sample was in excess of the 

water quality standard by a factor 2. Nickel contained in the seawater elutriate prepared from station SB10L 

exceeded water quality standards by a factor of 2. Mercury contained in the sample prepared from station 

SB11U was measured above the State standard by a factor of 16 but was below the Federal WQC. 

With respect to elutriate Hg data, it is important to note that the method specified rendered a laboratory 

reporting limit above the water quality standard by a factor of 8. Furthermore, measured Hg concentrations 

were all within a factor of 2 of the reporting limit. However, because chemical measurements of the 

background conditions require greater sensitivity, an alternate method (EPA Method 1620), providing a 

reporting limit in the sub part per trillion range, was employed to measure Hg at the ODMDS. 

4.2.2 SPP bioassay results 

Water column SPP tests were conducted in several batches on the full set of Casotte Landing slip area 

sediments. Batches were started on February 1, 2, 6, and 8, 2006. A re-test of the February 2, 2006 (Batch 2) 

and February 8, 2006 (Batch 4) A. punctulata assays were required because fertilization was insufficient. The 

assays were re-initiated on February 11, 2006. 

The tests showed little or no toxicity to the crustacean A. bahia (with the exception of minor toxicity in SB7L2) 

or fish Menidia beryllina. However, the SPP mixtures from selected sites were sufficiently toxic to the sea 

urchin larvae Arbacia punctulata to allow calculation of median lethal and effects concentration values (LC50

and EC50, respectively). Tables 4-10a, 4-10b, and 4-10c summarize species survivorship in the various SPP 

mixtures. Table 4-11 lists LC50 and EC50 values and supporting statistics are summarized in Tables 4-12a, 

4-12b, and 4-12c. Laboratory bench sheets are included in Appendix D. 

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Laboratory Control Findings 

Americamysis bahia. After 96 hours of exposure, survival in the laboratory controls was 98%, 98%, 92% and 

98% for Batches 1 through 4, respectively (Table 4-10a). All laboratory controls met the minimum test 

acceptability criterion of 90% survival. Survival in the dilution water control was 94%, 98%, 98%, and 96%, 

indicating that water from the disposal site used to dilute the suspended particulate phase solutions had no 

adverse impact on the outcome of the assays. 

Menidia beryllina. After 96 hours of exposure, M. beryllina survival in the laboratory controls was 100%, 100%, 

98% and 98% for Batches 1 through 4, respectively (Table 4-10b). All laboratory controls met the minimum 

test acceptability criterion of 90% survival. Survival in the dilution water control was 98%, 98%, 98%, and 90%, 

indicating that water from the disposal site used to dilute the suspended particulate phase solutions had no 

adverse impact on the outcome of the assays. 

Arbacia punctulata. The A. punctulata development assays were terminated after it was determined that at 

least 90% of the embryos in the laboratory control had reached the pluteus developmental (larval) stage. 

Three batches of the A. punctulata assay were conducted. The mean embryo survival in the laboratory 

controls was 93% in all three batches, with 92%, 90%, and 92% of the embryos exhibiting normal development 

for Batches 1 through 3, respectively (Table 4-10c). These results exceed minimum test acceptability criteria of 

90% embryo survival and 70% normal development. 

The mean embryo survival in the diluent control was 95%, 65%, and 81% for Batches 1 through 3, 

respectively. The mean normal development in the diluent control was 94%, 62%, and 76% for Batches 1 

through 3, respectively. 

Project site results

Undiluted SPP solutions prepared from a limited number of Casotte Landing slip area sediments had a 

significant impact on A. bahia and A. punctulata, while M. beryllina did not show any indication of a toxic effect 

(i.e., LC50 > 100%; Table 4-11). Survival of A. bahia was sufficiently reduced to result in an LC50 value of 

99.2% for the station SB7L sample. SPP solutions prepared from station SB4U and SB7U had a significant 

impact on survival and development of A. punctulata, with LC50s of 89% and 68%, respectively. Development 

EC50 (median effective concentration) values for A. punctulata were 68%, 60% and 51% for stations SB4U, 

SB7U and SC123, respectively. 

The first causative considerations in SPP toxicity generally relate to basic water quality conditions. Low 

dissolved oxygen or high ammonia levels unrelated to material contaminants can adversely affect the test 

organisms. In the case of A. punctulata, TSS can be a factor since these organisms are small spherical 

swimmers. In these SPP samples, basic water quality parameters were within the normal range during the 

tests where toxicity was observed. Ammonia levels monitored during the course of the assays were low 

(generally below 2 mg/L), indicating that ammonia was not likely to be a significant stressor in the SPP 

solutions. The highest ammonia levels measured during the assay were recorded for the SC123 sample (up 

to 8.7 mg/L in the A. punctulata assay), but these levels are still below the Federal acute WQC, which is 

approximately 27 mg/L at test condition salinity (30 ppt), pH (7.3), and temperature (20°C). 

4.3 Bioaccumulation potential 

This section presents Biota-Sediment Accumulation Factors (BSAFs) calculated for Casotte Landing materials 

and the bioaccumulation bioassay tissue testing data to address Casotte Landing bioaccumulation 

considerations. A subset of project parameters was measured in exposed tissue material, given the (clean) 

sediment chemistry results. The final CE SAM and EPA tissue analysis recommendations are summarized in 

Table 4-13. 

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4.3.1 BSAF findings 

Since the BSAF model is appropriate for hydrophobic organic compounds (HOCs), only PAHs have been 

included in this assessment. Furthermore, only station SB7U required PAH investigation per agency 

recommendations. Table 4-14 summarizes the PAH BSAFs calculated for Station SB7U and the reference 

sediments. BSAFs for detected PAH compounds were generally greater at the reference station than at SB7U. 

The greatest BSAF was 0.78 for indeno(1,2,3-cd)pyrene, far below the value of 4 which is often used to 

evaluate HOC risk associated with dredged materials (EPA and USACE, 1991). Based on BSAF calculations, 

the accumulation of PAHs in marine tissues exposed to Casotte Landing sediments would not be significant. 

4.3.2 28-day bioaccumulation bioassay 

To evaluate bioaccumulation potential of Casotte Landing sediments, the clam Macoma nasuta and the worm 

Nereis virens were exposed to material from the project stations. The clam assay was initiated on February 2, 

2006 and the worm assay was started on February 15, 2006. Laboratory bench sheets are included in 

Appendix D. M. nasuta and N. virens survival following a 28 day exposure to Casotte Landing sediments are 

provided in Tables 4-15a and 4-15b. 

Average survival for the clam assay was 95% in the laboratory control and 92% in the reference sample. Mean 

survival for the worm assay was 93% in the laboratory control and 95% in the reference sample. The clam 

survivorship in the project samples ranged from 87% in composite C3L2 to 96% in SB4U and SB7U. Worm 

survival ranged from 75% associated with samples C3L2 and SB7L, to 95% survival in station SB10L sample. 

Overall, clam and worm survival following a 28-day exposure period was very good relative to reference. 

Test organism tissues were analyzed for the chemical parameters listed in Table 4-13 to evaluate the 

bioaccumulative aspect of project material. The chemical results are provided on a wet weight basis in 

Tables 4-17 and 4-18. 

FDA action limit comparisons. Tissue chemistry data were compared to FDA action limits for those 

compounds that have established limits. In this case, Hg is the only FDA-relevant parameter. The Hg data 

were compared to the FDA threshold using upper confidence limit (UCL) statistical procedures. FDA limits are 

listed in Table 4-19, UCL test results are summarized in Table 4-20. 

The Hg UCLs for project site tissues were substantially less than the FDA action level (more than one order of 

magnitude less for N. virens and more than two orders of magnitude less for M. nasuta). Furthermore, Hg 

concentrations in the site-exposed tissues were generally the same as those in the reference-exposed and 

unexposed tissue concentrations, confirming that Hg bioaccumulation within site-exposed tissues is not an 

ecological or human health concern. 

Reference site comparisons. Site-exposed tissue data were compared to reference-exposed tissue data 

using t-tests whenever the concentration mean values for site-exposed tissues were greater than those of the 

mean reference-exposed tissue. Non-parametric tests were used whenever raw or log transformed data 

where not normally distributed (medians were compared for non-parametric tests). If less than 50 percent of 

the data were detected, then statistical analysis was not performed. Statistical significance of those cases 

where contaminants in the site-exposed tissues exceeded reference is summarized in Tables 4-21 and 4-22. 

Raw statistical data are provided in Appendix E. 

M. nasuta and N. virens tissue samples were analyzed for a wide range of chemical parameters although 

many were not detected, particularly in the worm tissue. Of the detected chemical parameters, many were at 

concentrations statistically equivalent to or lower than reference-exposed tissues, and these are summarized 

in Table 4-23. In the final analysis, the concentrations of five metals and seven PAH compounds were 

detected in site-exposed tissues at statistically greater levels than in reference-exposed tissues. To further 

evaluate the importance of these differences, the mean concentration values associated with each of these 

statistical conditions are provided in Table 4-24. 

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The metals As, Cd, Ni, Pb, and Sb were present at significantly greater concentrations in site versus 

reference-exposed tissues in one or more tissue types (clams or worms). In each case, however, these 

metals were at equivalent or higher concentrations in unexposed tissue material. The unexposed tissue 

material in this case is tissue from the same batch of test clams or worms used in the bioassay, and 

represents the concentration of metals in the tissue at the start of the test. 

The PAHs 2-methylnaphthalene, anthracene, chrysene, fluoranthene, fluorene, phenanthrene, and pyrene 

were detected in SB7U-exposed tissues and measured at concentrations that were significantly greater than 

reference-exposed tissue although most of these comparisons were made using data that were reported 

below the laboratory reporting limit. Furthermore, all PAHs at statistically greater concentrations in SB7Uexposed worm tissue relative to reference-exposed worm tissue were below unexposed worm tissue levels. 

Only clam tissue contained selected PAH compounds that were at higher concentrations than those in the 

unexposed clam tissue and of these, only fluoranthene and phenanthrene were consistently reported above 

laboratory reporting limits. Pyrene was detected in clam tissue above laboratory reporting limits in just two of 

the five SB7U replicates. 

Critical body residue (CBR) information available through ERDC provides an excellent way to evaluate the 

biological importance of contaminants found in animal tissues. For this analysis, the Environmental ResidueEffects Database (ERED) was searched for all marine organisms that have reported No Observable Effect 

Concentration (NOEC) data for the chemical parameters of interest. NOECs related to behavioral, 

reproductive, physiological/developmental, growth, and lethal effects are provided in Table 4-25. In cases 

where marine organism data were not available for a particular parameter of interest, freshwater animal data 

were obtained from ERED. 

In the final analysis of station SB7U, the compounds anthracene, chrysene, fluoranthene, fluorene, 

phenanthrene, and pyrene were measured in clam tissue at concentrations greater than in the referenceexposed and unexposed tissue. However, the available CBR data indicate that the observed concentrations 

are two to three orders of magnitude below available NOECs for marine organisms. Since corresponding 

marine organism data were not available, freshwater organism data were used to evaluate pyrene and this 

compound was also measured at concentrations within NOEC levels. Thus, based on available CBR 

information, the observed PAH concentrations measured in SB7U-exposed tissues did not accumulate to 

levels that would negatively affect marine organisms. 

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Table 4-1 Agency provided sample analysis recommendations 

Site identifier Sample ID 

Stations tested individually 

Upper site material 

SB4U SB4U2 

SB7U SB7U2 

SB9U SB9U2 

SB10U SB10U2 

SB11U SB11U2 

SB12U SB12U2 

Lower site material 

SB7L SB7L2 

SB10L SB10L2 

SB12L SB12L2 

Stations pooled for testing

Upper site material

SB1/SB2/SB3 C1U2 

SB5/SB6/SB8 C2U2 

Lower site material

SB1/SB2/SB3/SB4 C3L2 

SB5/SB6/SB8/SB9/SB11 C4L2 

Coastal site material 

SC1, SC2, SC3 SC123 

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Table 4-2 CLLNG Phase 1 Chemistry and Grain Size Results

Sample ID SB1U1 SB1L1 SB2U1 SB2L1 SB3U1 SB3L1 SB4UU1 SB4U1 SB4L1 SB5U

Sampling Interval Upper Limit (bgs) Feet 10 15 15 19 18 20.5 10 15 20 10 Sampling Interval Lower Limit (bgs) Feet 15 60 19 60 20.5 60 15 20 60 15.5 Chemical Name UnitPHYSICAL TESTSMOISTURE CONTENT % 22 45 20 38 22 38 96 17 38 19 GRAVEL % 0100000010SAND % 63 37 69 55 54 55 34 65 47 61 SILT + CLAY % 37 62 31 45 46 45 66 35 52 39 TOTAL ORGANIC CARBON % 0.13 0.85 0.09 0.66 0.08 0.89 5.40 0.08 0.56 0.17 METALSALUMINUM mg/kg 21800 54700 20900 40600 26300 41100 37100 14000 53000 13000 ANTIMONY mg/kg 0.05 J,N 0.06 N 0.05 U,N 0.05 N 0.05 N 0.04 J,N 0.08 N 0.06 U,N 0.11 N 0.05 JARSENIC mg/kg 2.28 5.26 1.14 4.62 2.28 4.76 9.13 * 0.68 * 4.97 * 1.15 

BERYLLIUM mg/kg 0.103 0.803 0.068 0.621 0.166 0.753 0.658 0.07 0.722 0.057 CADMIUM mg/kg 0.028 J 0.134 0.028 J 0.107 0.032 J 0.113 0.09 0.024 J 0.093 0.041 CHROMIUM mg/kg 9.04 14.3 5.74 12.1 11 13.8 14.8 5.43 9.86 47.1 COPPER mg/kg 1.12 7.54 0.68 5.77 1.62 5.27 3.67 0.79 7.22 1.04 LEAD mg/kg 4.71 10.2 3.78 8.41 5.89 8.52 10.2 2.98 8.7 2.74 MERCURY mg/kg 0.009 J 0.022 0.019 U 0.018 J 0.019 U 0.019 J 0.158 0.019 U 0.019 J 0.009 NICKEL mg/kg 1.98 11 1.1 9.05 1.92 9.54 7.08 1.45 8.26 1.7 SELENIUM mg/kg 0.4 J 0.4 J 0.3 J 0.4 J 0.4 J 0.5 J 1.2 0.3 J 0.6 J 0.6 J SILVER mg/kg 0.011 J 0.038 0.007 J 0.029 0.013 J 0.025 0.033 0.023 U 0.03 0.008 THALLIUM mg/kg 0.085 0.182 0.041 0.148 0.077 0.185 0.129 0.05 0.125 0.034 ZINC mg/kg 3.71 31.8 2.21 26.8 5.51 30 15.4 4.5 26.4 4.7 AVS/SEMCADMIUM umol/g 0.0006 U 0.002 0.0006 U 0.001 0.0006 U 0.001 0.0008 U 0.0006 U 0.002 0.0006 COPPER umol/g 0.006 0.090 0.005 0.074 0.013 0.019 .003 U 0.005 0.060 0.013 LEAD umol/g 0.012 0.031 0.009 0.028 0.012 0.016 0.030 .0058 U 0.023 0.009 MERCURY umol/g 0.00005 U 0.00006 U 0.00004 U 0.00005 U 0.00004 U 0.00005 U 0.00007 U 0.00005 U 0.00005 U 0.00004 NICKEL umol/g 0.015 0.111 .003 U 0.095 .003 U 0.051 0.041 0.005 0.082 0.017 ZINC umol/g 0.031 0.413 0.003 0.332 0.015 0.340 0.138 0.020 0.326 0.025 TOTAL METALS umol/g 0.064 0.646 0.017 0.530 0.040 0.427 0.209 0.030 0.492 0.063 ACID VOLATILE SULFIDE umol/g 0.028 U 0.028 U 0.028 U 0.028 U 0.037 0.025 U 0.031 U 0.031 U 0.031 U 0.031 SEM:AVS RATIO umol/g 4.6 46.2 1.2 37.9 1.1 17.1 13.4 1.9 31.5 4.0 NONMETALS/OTHERSULFIDE ug/kg 0.8 U 11.5 0.21 J 6.4 2.9 8.6 9.6 2.1 2.4 1.0 U AMMONIA ug/kg 1.3 6.7 1.7 5.9 2.6 6.6 60.9 2.3 4.8 1.3 NITRATE ug/kg 0.03 J 0.06 J 0.5 U 0.5 U 0.5 U 0.5 U 0.2 U 0.2 U 0.2 U 0.2 U NITRITE ug/kg 0.04 J 0.03 J 0.03 J 0.04 J 0.03 J 0.03 J 1.9 U 1.9 U 1.9 U 1.9 U NITRATE + NITRITE ug/kg 0.07 J 0.09 J 0.5 U 0.04 J 0.5 U 0.5 U 0.2 U 0.2 U 0.2 U 0.2 U NITROGEN, KJELDAHL, TOTAL ug/kg 86 385 82 269 113 359 2340 54.8 304 75 PHOSPHOROUS ug/kg 13.0 88.2 11.1 93.8 8.1 82.5 53.3 6.4 90.6 13.1 CYANIDE ug/kg 0.2 U 0.2 U 0.2 U 0.2 U 0.06 J 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U OXIDATION REDUCTION POTENTIAL MILLIVOLTS 91.4 66.3 110 35.8 94.9 64.5 44.9 96.2 80.1 85.8 PH pH UNITS 7.57 8.09 7.26 7.73 7.42 7.43 8.01 7.77 8.10 7.51 PAHs1-METHYLNAPHTHALENE ug/kg 3.1 U 3.7 U 0.36 J 0.39 J 3.1 U 0.41 J 0.83 J 0.47 J 0.67 J 0.51 J 2-METHYLNAPHTHALENE ug/kg 3.1 U 3.7 U 0.58 J 0.60 J 3.1 U 0.55 J 1.3 J 0.65 J 1.1 J 0.72 J ACENAPHTHENE ug/kg 3.1 U 3.7 U 3.0 U 3.5 U 3.1 U 3.4 U 0.39 J 3.0 U 0.31 J 0.45 J ACENAPHTHYLENE ug/kg 3.1 U 3.7 U 0.31 J 3.5 U 3.1 U 3.4 U 4.8 U 3.0 U 0.33 J 3.0 U ANTHRACENE ug/kg 3.1 U 3.7 U 0.34 J 3.5 U 3.1 U 0.34 J 4.8 U 3.0 U 0.50 J 0.36 J BENZO(A)ANTHRACENE ug/kg 3.1 U 3.7 U 0.94 J 3.5 U 3.1 U 0.60 J 4.8 U 3.0 U 3.4 U 1.8 J BENZO(A)PYRENE ug/kg 0.28 J 3.7 U 0.82 J 3.5 U 3.1 U 0.42 J 4.8 U 3.0 U 3.4 U 1.6 J BENZO(B)FLUORANTHENE ug/kg 3.1 U 3.7 U 0.83 J 3.5 U 3.1 U 3.4 U 0.91 J 3.0 U 3.4 U 1.8 J BENZO(G,H,I)PERYLENE ug/kg 0.31 J 3.7 U 0.65 J 3.5 U 3.1 U 0.53 J 0.48 J 3.0 U 0.52 J 1.4 J BENZO(K)FLUORANTHENE ug/kg 3.1 U 3.7 U 0.65 J 3.5 U 3.1 U 3.4 U 4.8 U 3.0 U 3.4 U 1.2 J CHRYSENE ug/kg 3.1 U 3.7 U 0.81 J 3.5 U 3.1 U 0.58 J 4.8 U 3.0 U 3.4 U 1.8 J DIBENZ(A,H)ANTHRACENE ug/kg 3.1 U 3.7 U 3.0 U 3.5 U 3.1 U 3.4 U 4.8 U 3.0 U 3.4 U 3.0 U FLUORANTHENE ug/kg 0.45 J 0.51 J 1.7 J 3.5 U 3.1 U 1.1 J 1.4 J 0.41 J 0.72 J 3.5 FLUORENE ug/kg 3.1 U 3.7 U 3.0 U 3.5 U 3.1 U 0.38 J 0.46 J 3.0 U 0.56 J 0.28 J INDENO(1,2,3-CD)PYRENE ug/kg 3.1 U 3.7 U 0.63 J 3.5 U 3.1 U 0.40 J 0.47 J 3.0 U 0.36 J 1.5 J NAPHTHALENE ug/kg 1.3 J 1.6 J 1.6 J 1.9 J 1.2 J 1.4 J 3.8 J 2.2 J 2.7 J 2.2 J PHENANTHRENE ug/kg 3.1 U 0.51 J 1.2 J 0.68 J 3.1 U 1.1 J 0.87 J 0.48 J 0.98 J 1.8 J PYRENE ug/kg 3.1 U 3.7 U 2.4 J 3.5 U 3.1 U 0.95 J 3.6 J 3.0 U 0.62 J 2.4 J 

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Do Not Release Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Table 4-2 CLLNG Phase 1 Chemistry and Grain Size Results

Sample ID SB8U1 SB8L1 SB9U1 SB9L1 SB10U1A SB10U1B SB10L1 SB11U1 SB11

Sampling Interval Upper Limit (bgs) Feet 10.7 13.5 11 13.5 10 10 16.5 10 16.Sampling Interval Lower Limit (bgs) Feet 13.5 60 13.5 60 16.5 16.5 25 16.5 60 Chemical Name UnitPHYSICAL TESTSMOISTURE CONTENT % 22 36 25 42 21 21 58 20 36 GRAVEL % 0 0 0 0 0 0 0 0 2 SAND % 73 61 59 46 76 74 9 95 52 SILT + CLAY % 27 39 41 54 24 26 91 5 46 TOTAL ORGANIC CARBON % 0.17 0.59 0.23 0.59 0.10 0.15 0.37 0.04 J 0.7METALSALUMINUM mg/kg 15900 35800 30000 47600 22000 20500 75600 2910 3070ANTIMONY mg/kg 0.04 J,N 0.04 J,N 0.03 J,N 0.06 N 0.04 J,N 0.04 J,N 0.13 N 0.05 U,N 0.04 ARSENIC mg/kg 1.54 4.49 2.26 * 4.69 * 2.45 2.21 5 0.36 J 3.4BERYLLIUM mg/kg 0.097 0.56 0.374 0.772 0.094 0.118 1.5 0.024 0.52CADMIUM mg/kg 0.044 J 0.093 0.086 0.148 0.029 J 0.037 J 0.394 0.026 J 0.10CHROMIUM mg/kg 4.54 8.67 7.37 12.9 7.26 9.91 24.9 2.13 11.COPPER mg/kg 1.15 5.37 4.43 8.56 0.69 0.79 17 0.43 4.3LEAD mg/kg 3.91 7.24 6.1 9.71 3.59 4.62 19.7 1.52 7.7MERCURY mg/kg 0.02 U 0.016 J 0.013 J 0.021 0.011 J 0.009 J 0.032 0.019 U 0.015 NICKEL mg/kg 1.47 8.24 6.57 11.2 1.28 2.4 23.4 0.79 7.1SELENIUM mg/kg 0.7 J 0.5 J 0.6 J 0.5 J 1 U 0.3 J 0.6 J 1 U 0.3 SILVER mg/kg 0.01 J 0.027 0.02 J 0.036 0.008 J 0.007 J 0.077 0.004 J 0.03THALLIUM mg/kg 0.068 0.124 0.098 0.148 0.046 0.071 0.349 0.014 J 0.13ZINC mg/kg 2.75 24.2 18.1 31.5 3.06 33.8 57.3 1.71 20.AVS/SEMCADMIUM umol/g 0.0006 U 0.002 0.001 0.003 0.0006 U 0.0006 U 0.003 0.0004 U 0.00COPPER umol/g 0.006 0.063 0.057 0.110 0.005 0.003 0.192 0.003 0.03LEAD umol/g 0.015 0.024 0.019 0.032 0.008 0.009 0.048 0.005 U 0.02MERCURY umol/g 0.00005 U 0.00005 U 0.00005 U 0.00001 U 0.00005 U 0.00005 U 0.00009 U 0.00004 U 0.0000NICKEL umol/g 0.005 U 0.087 0.080 0.124 0.0034 U 0.003 U 0.204 0.003 U 0.05ZINC umol/g 0.006 0.326 0.251 0.413 0.026 2.570 0.565 0.008 0.23TOTAL METALS umol/g 0.028 0.501 0.408 0.682 0.039 2.582 1.012 0.011 0.34ACID VOLATILE SULFIDE umol/g 0.028 U 0.028 U 0.031 U 0.031 U 0.028 U 0.028 U 0.028 U 0.028 U 0.028 SEM:AVS RATIO umol/g 2.0 35.8 26.1 43.7 2.8 184.4 72.3 0.8 24.NONMETALS/OTHERSULFIDE ug/kg 0.8 U 7.2 1.5 8.6 0.8 1.1 10.4 0.9 6.7 AMMONIA ug/kg 3.7 5.0 4.7 5.9 7.7 7.9 3.9 0.3 6.0 NITRATE ug/kg 0.03 J 0.03 J 0.2 U 0.2 U 0.05 J 0.03 J 0.06 J 0.5 U 0.5 NITRITE ug/kg 0.03 J 0.06 J 1.9 U 1.9 U 0.03 J 0.05 J 0.02 J 0.03 J 0.05 NITRATE + NITRITE ug/kg 0.06 J 0.09 J 0.2 U 0.2 U 0.08 J 0.08 J 0.08 J 0.5 U 0.06 NITROGEN, KJELDAHL, TOTAL ug/kg 108 314 163 335 79 154 603 43 272 PHOSPHOROUS ug/kg 10.9 103 28.9 169 16.4 12.3 149 3.7 75.CYANIDE ug/kg 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 U 0.2 OXIDATION REDUCTION POTENTIAL MILLIVOLTS 95.1 81.9 91.9 73.0 87.5 88.2 -9.8 140 73.PH pH UNITS 7.92 7.81 7.05 7.82 8.01 7.92 6.65 8.09 7.7PAHs1-METHYLNAPHTHALENE ug/kg 3.1 U 3.6 U 2.5 U 0.68 J 3.0 U 0.37 J 0.55 J 0.66 J 0.39 2-METHYLNAPHTHALENE ug/kg 0.64 J 3.6 U 2.5 U 1.1 J 0.45 J 0.49 J 0.72 J 1.3 J 0.55 ACENAPHTHENE ug/kg 0.23 J 3.6 U 2.5 U 0.27 J 3.0 U 3.1 U 4.0 U 3.0 U 3.3 ACENAPHTHYLENE ug/kg 3.1 U 3.6 U 2.5 U 3.6 U 3.0 U 3.1 U 4.0 U 3.0 U 3.3 ANTHRACENE ug/kg 1.7 J 3.6 U 2.5 U 3.6 U 3.0 U 3.1 U 4.0 U 0.67 J 3.3 BENZO(A)ANTHRACENE ug/kg 1.3 J 3.6 U 2.5 U 0.76 J 0.28 J 0.24 J 0.49 J 1.9 J 3.3 BENZO(A)PYRENE ug/kg 1.1 J 3.6 U 2.5 U 3.6 U 0.29 J 0.39 J 0.72 J 2.1 J 3.3 BENZO(B)FLUORANTHENE ug/kg 1.5 J 3.6 U 2.5 U 3.6 U 3.0 U 3.1 U 4.0 U 1.5 J 3.3 BENZO(G,H,I)PERYLENE ug/kg 1.0 J 0.33 J 0.44 J 0.45 J 0.64 J 0.43 J 1.1 J 2.5 J 3.3 BENZO(K)FLUORANTHENE ug/kg 0.97 J 3.6 U 2.5 U 3.6 U 3.0 U 3.1 U 0.60 J 1.1 J 3.3 CHRYSENE ug/kg 1.8 J 3.6 U 2.5 U 3.6 U 3.0 U 3.1 U 4.0 U 3.7 3.3 DIBENZ(A,H)ANTHRACENE ug/kg 0.55 J 3.6 U 2.5 U 3.6 U 3.0 U 3.1 U 0.48 J 0.82 J 3.3 FLUORANTHENE ug/kg 1.8 J 3.6 U 2.5 U 1.7 J 0.73 J 0.64 J 0.77 J 1.3 J 3.3 FLUORENE ug/kg 0.28 J 3.6 U 2.5 U 0.35 J 3.0 U 3.1 U 4.0 U 3.0 U 3.3 INDENO(1,2,3-CD)PYRENE ug/kg 0.91 J 3.6 U 2.5 U 0.36 J 0.47 J 0.30 J 0.95 J 0.94 J 3.3 NAPHTHALENE ug/kg 1.8 J 1.5 J 1.1 J 3.2 J 1.7 J 1.4 J 1.9 J 1.7 J 1.3 PHENANTHRENE ug/kg 0.59 J 3.6 U 2.5 U 1.9 J 0.73 J 0.60 J 0.72 J 1.1 J 3.3 PYRENE ug/kg 1.4 J 3.6 U 2.5 U 1.1 J 3.0 U 0.45 J 0.68 J 1.5 J 3.3 

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Do Not Release Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Table 4-2 CLLNG Phase 1 Chemistry and Grain Size Results

Sample ID SB1U1 SB1L1 SB2U1 SB2L1 SB3U1 SB3L1 SB4UU1 SB4U1 SB4L1 SB5U

Sampling Interval Upper Limit (bgs) Feet 10 15 15 19 18 20.5 10 15 20 10 Sampling Interval Lower Limit (bgs) Feet 15 60 19 60 20.5 60 15 20 60 15.5 Chemical Name UnitLMW PAH1 ug/kg 12 13 7.4 11 12 7.6 12 9.8 7.2 7.8 

HMW PAH1 ug/kg 12 17 11 18 16 9.7 19 14 12 19 PAH Sum1 ug/kg 24 30 18 28 28 17 31 24 20 26 PESTICIDES2,4-DDD ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 Ui 3.0 U 3.4 U 3.0 U 2,4-DDE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U 2,4-DDT ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U 4,4-DDD ug/kg 5.0 Ui 5.0 U 5.0 U 5.0 U 5.0 U 5.0 Ui 0.40 J 3.0 U 3.4 U 3.0 U 4,4-DDE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 0.34 J 3.0 U 3.4 U 3.0 U 4,4-DDT ug/kg 5.0 U 5.0 U 5.0 Ui 5.0 U 5.0 Ui 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U ALDRIN ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U ALPHA-BHC ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U ALPHA-CHLORDANE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U BETA-BHC ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U CIS-NONACHLOR ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U DELTA-BHC ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U DIELDRIN ug/kg 5.0 U 5.0 Ui 5.0 U 5.0 U 5.0 U 5.0 U 4.8 Ui 3.0 U 3.4 U 3.0 U ENDOSULFAN I ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U ENDOSULFAN II ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 0.41 J 3.0 U 3.4 U 3.0 U ENDOSULFAN SULFATE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 Ui 3.0 U 3.4 U 3.0 U ENDRIN ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U ENDRIN ALDEHYDE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 Ui 3.0 U 3.4 U 3.0 U ENDRIN KETONE ug/kg 5.0 U 5.0 Ui 5.0 U 5.0 U 5.0 U 5.0 U 4.8 Ui 3.0 U 3.4 Ui 3.0 UGAMMA-BHC (LINDANE) ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U GAMMA-CHLORDANE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U HEPTACHLOR ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U HEPTACHLOR EPOXIDE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 Ui 3.0 U 3.4 U 3.0 U HEXACHLOROBENZENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U METHOXYCHLOR ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 Ui 3.0 U 3.4 Ui 3.0 U MIREX ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 Ui 3.0 U 3.4 U 3.0 U OXYCHLORDANE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 4.8 U 3.0 U 3.4 U 3.0 U TOXAPHENE ug/kg 250 U 250 U 250 U 250 Ui 250 Ui 250 U 240 Ui 150 U 170 U 150 UTRANS-NONACHLOR ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCBsPCB 8 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 18 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 28 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.63 U 0.72 U 0.63 U PCB 44 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 49 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 52 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 66 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 77 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 87 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 101 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.12 J PCB 105 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 Ui 0.59 U 0.68 U 0.59 U PCB 118 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 126 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 128 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 Ui 0.59 U 0.68 U 0.59 U PCB 138 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.37 J PCB 153 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 UPCB 156 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 169 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 170 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.21 JPCB 180 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.50 J PCB 183 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.12 J PCB 184 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 187 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.29 J PCB 195 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 206 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB 209 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 0.95 U 0.59 U 0.68 U 0.59 U PCB Sum2 ug/kg 13 13 13 13 13 13 12 7.7 8.9 7.5 

7/13/2006Q:\mw97\Projects\01231021\0049\Table 4-2 - sed.xls 

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Do Not Release Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Table 4-2 CLLNG Phase 1 Chemistry and Grain Size Results

Sample ID SB8U1 SB8L1 SB9U1 SB9L1 SB10U1A SB10U1B SB10L1 SB11U1 SB11

Sampling Interval Upper Limit (bgs) Feet 10.7 13.5 11 13.5 10 10 16.5 10 16.Sampling Interval Lower Limit (bgs) Feet 13.5 60 13.5 60 16.5 16.5 25 16.5 60 Chemical Name UnitLMW PAH1 ug/kg 8.3 14 9.9 11 10 9.1 12 9.9 10 

HMW PAH1 ug/kg 12 17 12 13 9.9 8.7 9.8 17 17 PAH Sum1 ug/kg 21 31 22 24 20 18 22 27 27 PESTICIDES2,4-DDD ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 2,4-DDE ug/kg 5.0 U 5.0 Ui 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 2,4-DDT ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 4,4-DDD ug/kg 5.0 Ui 5.0 Ui 3.2 U 3.6 U 5.0 Ui 5.0 Ui 5.0 U 5.0 U 5.0 4,4-DDE ug/kg 5.0 Ui 5.0 U 3.2 U 3.6 U 5.0 Ui 5.0 Ui 5.0 U 5.0 U 5.0 4,4-DDT ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ALDRIN ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ALPHA-BHC ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ALPHA-CHLORDANE ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 BETA-BHC ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 CIS-NONACHLOR ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 Ui 1.0 Ui 1.0 U 1.0 U 1.0 DELTA-BHC ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 DIELDRIN ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ENDOSULFAN I ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ENDOSULFAN II ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ENDOSULFAN SULFATE ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ENDRIN ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ENDRIN ALDEHYDE ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 Ui 5.0 U 5.0 U 5.0 ENDRIN KETONE ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 GAMMA-BHC (LINDANE) ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 GAMMA-CHLORDANE ug/kg 5.0 U 5.0 U 3.2 U 3.6 Ui 5.0 U 5.0 U 5.0 U 5.0 U 5.0 HEPTACHLOR ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 HEPTACHLOR EPOXIDE ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 HEXACHLOROBENZENE ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 METHOXYCHLOR ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 MIREX ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 OXYCHLORDANE ug/kg 5.0 U 5.0 U 3.2 U 3.6 U 5.0 Ui 5.0 Ui 5.0 U 5.0 U 5.0 TOXAPHENE ug/kg 250 U 250 U 160 U 180 U 250 Ui 250 U 250 U 250 Ui 250 TRANS-NONACHLOR ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCBsPCB 8 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 Ui 1.0 PCB 18 (BZ) ug/kg 1.0 Ui 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 Ui 1.0 PCB 28 (BZ) ug/kg 1.0 U 1.0 U 0.67 U 0.76 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 44 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 49 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 52 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 66 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 77 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 87 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 101 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 105 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 118 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 126 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 128 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 138 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 153 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 156 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 169 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 170 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 180 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 183 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 184 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 187 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 195 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 206 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 209 (BZ) ug/kg 1.0 U 1.0 U 0.64 U 0.72 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB Sum2 ug/kg 13 13 8.3 9.4 13 13 13 13 13 

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Table 4-2 CLLNG Phase 1 Chemistry and Grain Size Results

Sample ID SB1U1 SB1L1 SB2U1 SB2L1 SB3U1 SB3L1 SB4UU1 SB4U1 SB4L1 SB5U

Sampling Interval Upper Limit (bgs) Feet 10 15 15 19 18 20.5 10 15 20 10 Sampling Interval Lower Limit (bgs) Feet 15 60 19 60 20.5 60 15 20 60 15.5 Chemical Name UnitVOLATILESBENZENE ug/kg 4.5 U 4.8 U 4.1 U 5.2 U 4.6 U 5.6 U 9.1 U 4.1 U 5.2 U 4.6 U CHLOROFORM ug/kg 4.5 U 4.8 U 4.1 U 5.2 U 4.6 U 5.6 U 9.1 U 4.1 U 5.2 U 4.6 U ETHYLBENZENE ug/kg 4.5 U 4.8 U 4.1 U 5.2 U 4.6 U 5.6 U 9.1 U 4.1 U 5.2 U 4.6 U TETRACHLOROETHENE ug/kg 4.5 U 4.8 U 4.1 U 5.2 U 4.6 U 5.6 U 9.1 U 4.1 U 5.2 U 4.6 U TOLUENE ug/kg 1.1 J 4.8 U 4.1 U 5.2 U 4.6 U 5.6 U 9.1 U 4.1 U 5.2 U 4.6 U TRICHLOROETHENE ug/kg 4.5 U 4.8 U 4.1 U 5.2 U 4.6 U 5.6 U 9.1 U 4.1 U 5.2 U 4.6 U XYLENES (TOTAL) ug/kg 9.0 U 9.6 U 8.2 U 10 U 9.2 U 11 U 18 U 8.2 U 10 U 9.2 U TPHRESIDUAL RANGE ORGANICS mg/kg 6.7 J 22 J 16 J 29 Z 15 J 28 Z 290 Z 5.9 J 14 J 6.2 J TPH AS DIESEL mg/kg 25 U 30 U 24 U 27 U 25 U 28 U 24 J 24 U 28 U 25 U 

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Table 4-2 CLLNG Phase 1 Chemistry and Grain Size Results

Sample ID SB8U1 SB8L1 SB9U1 SB9L1 SB10U1A SB10U1B SB10L1 SB11U1 SB11

Sampling Interval Upper Limit (bgs) Feet 10.7 13.5 11 13.5 10 10 16.5 10 16.Sampling Interval Lower Limit (bgs) Feet 13.5 60 13.5 60 16.5 16.5 25 16.5 60 Chemical Name UnitVOLATILESBENZENE ug/kg 1.2 J 5.3 U 4.5 U 5.7 U 4.6 U 3.7 U NA 5.1 U 4.6 CHLOROFORM ug/kg 4.6 U 5.3 U 4.5 U 5.7 U 4.6 U 3.7 U NA 5.1 U 4.6 ETHYLBENZENE ug/kg 2.0 J 5.3 U 4.5 U 5.7 U 4.6 U 3.7 U NA 5.1 U 4.6 TETRACHLOROETHENE ug/kg 4.6 U 5.3 U 4.5 U 5.7 U 4.6 U 3.7 U NA 5.1 U 4.6 TOLUENE ug/kg 4.6 U 1.4 J 4.5 U 5.7 U 4.6 U 3.7 U NA 5.1 U 4.6 TRICHLOROETHENE ug/kg 4.6 U 5.3 U 4.5 U 5.7 U 4.6 U 3.7 U NA 5.1 U 4.6 XYLENES (TOTAL) ug/kg 9.2 U 11 U 9.0 U 11 U 9.2 U 7.4 U NA 10 U 9.2 TPHRESIDUAL RANGE ORGANICS mg/kg 6.9 J 18 J 12 J 16 J 10 J 9.6 J 16 J 15 J 47 TPH AS DIESEL mg/kg 26 U 29 U 27 U 30 U 25 U 25 U 32 U 23 U 4.6 Bold blue values exceed ER-L sediment screening values.Brackets [ ] represent ERLQ as the sediment value/screening value quotient.

1PAH summation of Low Molecular Weight PAHs, High Molecular Weight PAHs, and Total PAHs; 1/2 RL used in the summation in non-detect cases.2PCB summation using 1/2 RL in non-detect cases.3 Sediment core depth intervals are based on MLLW, not ground surface.

Data Qualifiers:U: Undetected; parameter was not detected above the laboratory RL.*: The duplicate analysis was not within control limits. J: The result is an estimated concentration that is less than the RL but greater than or equal to the MDL.P: The GC confirmation criteria were exceeded. The RPD is greater than 40% between the two analytical results (25% for CLP Pesticides).i: The RL/MDL has been elevated, due to a chromatographic interference.N: MS/MSD exceed acceptance criteria.Z: The chromatoagraphic fingerprint does not resemble a petroleum product.NA: Not Analyzed. Station SB10L VOC sample was lost and VOC analysis of aquatic sites (SC123, RO) was not specified/required.

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Table 4-3 CLLNG Phase 2 Chemistry and Grain Size Results

Sample ID C1U2 C2U2A C2U2B SB4U2 SB7U2 SB9U2 SB10U2 SB11U2 SB12U2 C3

Chemical Name UnitPHYSICAL TESTSMOISTURE CONTENT % 21 19 20 17 25 20 19 19 30 3GRAVEL % 0 00000000SAND % 76 80 79 68 76 59 74 94 25 4SILT + CLAY % 24 20 21 32 24 41 26 6 75 5

TOTAL ORGANIC CARBON % 0.17 0.07 0.09 0.10 0.20 0.24 0.10 0.11 0.17 0.METALSALUMINUM mg/kg 11600 17400 17300 12400 19400 27200 18800 3110 51500 41ANTIMONY mg/kg 0.06 U,N 0.06 U,N 0.06 U,N 0.06 U,N 0.06 U,N 0.05 U,N 0.06 U,N 0.06 U,N 0.05 U,N 0.06 

ARSENIC mg/kg 1.2 0.69 1.36 0.82 0.66 2.34 1.8 0.24 J 2.11 4.BERYLLIUM mg/kg 0.1 0.081 0.071 0.066 0.047 0.436 0.086 0.017 J 1.28 0.7CADMIUM mg/kg 0.01 J 0.06 U 0.062 U 0.059 U 0.062 U 0.068 0.06 U 0.059 U 0.017 J 0.1CHROMIUM mg/kg 5.35 7.09 7.09 5.41 19 12.4 8.13 1.92 15.7 18COPPER mg/kg 0.8 0.72 0.77 0.67 0.89 4.45 0.76 0.4 8.4 6.LEAD mg/kg 2.73 3.79 3.59 3.05 3.68 5.95 3.5 1.08 12.3 9.MERCURY mg/kg 0.011 J 0.009 J 0.009 J 0.01 J 0.015 J 0.02 0.015 J 0.008 J 0.024 0.0NICKEL mg/kg 1.69 1.87 1.3 1.34 2.24 6.8 1.51 0.57 2.97 11SELENIUM mg/kg 1.2 U 1.2 U 1.2 U 1.2 U 1.2 U 0.5 J 1.2 U 1.2 U 0.6 J 0.SILVER mg/kg 0.009 J 0.007 J 0.005 J 0.011 J 0.179 0.028 0.006 J 0.003 J 0.067 0.0THALLIUM mg/kg 0.048 0.043 0.037 0.038 0.024 J 0.088 0.038 0.024 U 0.093 0.1ZINC mg/kg 5 3.8 2.9 4 2.6 18.9 3.5 1.3 11.9 34AVS/SEMCADMIUM umol/g 0.0005 U 0.0005 U 0.0005 U 0.0004 U 0.0005 U 0.001 0.0005 U 0.0005 U 0.0006 U 0.00COPPER umol/g 0.006 0.005 0.005 0.006 0.011 0.104 0.008 0.003 0.057 0.0LEAD umol/g 0.008 0.009 0.008 0.005 0.010 0.028 0.010 0.005 U 0.025 0.0MERCURY umol/g 0.00004 U 0.00004 U 0.00004 U 0.00004 U 0.00004 U 0.00004 U 0.00004 U 0.00004 U 0.00005 U 0.000NICKEL umol/g 0.007 0.003 U 0.003 U 0.0034 U 0.027 0.118 0.005 0.003 0.009 0.1ZINC umol/g 0.026 0.005 0.005 0.009 0.028 0.425 0.017 0.011 0.052 0.4TOTAL METALS umol/g 0.047 0.018 0.018 0.021 0.076 0.675 0.040 0.017 0.142 0.7ACID VOLATILE SULFIDE umol/g 0.028 U 0.028 U 0.028 U 0.028 U 0.028 U 0.028 U 0.028 U 0.028 U 0.028 U 0.02SEM:AVS RATIO umol/g 3.4 1.3 3.4 1.5 5.4 48.2 2.9 1.2 10.1 50NONMETALS/OTHER

SULFIDE mg/kg 1.2 0.9 U 0.6 J 1.1 2.1 0.5 J 1.3 0.9 U 22.3 7AMMONIA mg/kg 4.3 2.9 3.5 1.5 18.3 6.6 7.9 0.3 J 3.1 6NITRATE mg/kg 0.5 U 0.09 J 0.08 J 0.08 J 0.08 J 0.07 J 0.5 U 0.5 U 0.5 U 0.0NITRITE mg/kg 0.5 U 0.5 U 0.5 U 0.5 U 0.5 U 0.5 U 0.5 U 0.5 U 0.5 U 0.5 NITRATE + NITRITE mg/kg 0.5 U 0.09 J 0.08 J 0.08 J 0.08 J 0.07 J 0.5 U 0.5 U 0.5 U 0.0NITROGEN, KJELDAHL, TOTAL mg/Kg 116 104 168 85 139 185 103 60 270 3PHOSPHOROUS mg/Kg 21.0 5.5 6.5 9.7 16.8 37.1 16.1 5.6 41.2 82CYANIDE mg/kg 0.3 U 0.3 U 0.3 U 0.3 U 0.3 U 0.3 U 0.3 U 0.3 U 0.3 U 0.3 OXIDATION REDUCTION POTENTIAL MILLIVOLTS 137 147 140 120 109 131 124 135 118 52PH pH UNITS 7.75 7.41 7.33 7.43 9.58 7.35 8.00 8.20 7.48 7.

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Table 4-3 CLLNG Phase 2 Chemistry and Grain Size Results

Sample ID C1U2 C2U2A C2U2B SB4U2 SB7U2 SB9U2 SB10U2 SB11U2 SB12U2 C3

Chemical Name Unit

PAHs1-METHYLNAPHTHALENE ug/kg 0.54 J 0.40 J 0.51 J 0.54 J 13 0.60 J 0.56 J 0.98 J 0.51 J 0.52-METHYLNAPHTHALENE ug/kg 0.67 J 0.59 J 0.62 J 0.69 J 13 0.77 J 0.82 J 2.2 J 0.70 J 0.7ACENAPHTHENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 20 0.46 J 5.0 U 5.0 U 5.0 U 5.0 ACENAPHTHYLENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 0.34 J 0.33 J 5.0 U 5.0 U 5.0 U 5.0 ANTHRACENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 3.5 J 0.88 J 0.30 J 0.54 J 5.0 U 5.0 BENZO(A)ANTHRACENE ug/kg 5.0 U 0.26 J 5.0 U 5.0 U 1.5 J 1.3 J 0.81 J 4.8 J 0.45 J 5.0 BENZO(A)PYRENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 0.71 J 0.66 J 0.61 J 8.0 0.44 J 5.0 BENZO(B)FLUORANTHENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 0.96 J 1.1 J 0.85 J 3.9 J 1.3 J 5.0 BENZO(G,H,I)PERYLENE ug/kg 5.0 U 0.95 J 5.0 U 5.0 U 0.78 J 0.66 J 1.2 J 9.4 2.4 J 0.6BENZO(K)FLUORANTHENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 0.84 J 0.70 J 0.52 J 1.7 J 0.87 J 0.5CHRYSENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 1.6 J 1.3 J 0.91 J 6.1 0.75 J 5.0 DIBENZ(A,H)ANTHRACENE ug/kg 5.0 U 0.57 J 5.0 U 5.0 U 5.0 U 5.0 U 0.64 J 3.5 J 5.0 U 5.0 FLUORANTHENE ug/Kg 0.45 J 0.59 J 0.58 J 5.0 U 7.3 3.0 J 2.5 J 1.0 J 0.75 J 0.5FLUORENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 13 0.58 J 0.28 J 0.27 J 5.0 U 5.0 INDENO(1,2,3-CD)PYRENE ug/kg 5.0 U 0.75 J 5.0 U 5.0 U 0.75 J 0.53 J 0.92 J 2.0 J 1.3 J 0.3NAPHTHALENE ug/Kg 2.3 J 3.8 J 5.4 2.5 J 8.2 2.5 J 2.4 J 3.3 J 2.4 J 2.PHENANTHRENE ug/kg 5.0 U 0.66 J 0.78 J 0.42 J 20 2.6 J 2.6 J 1.8 J 0.50 J 0.7PYRENE ug/kg 5.0 U 0.59 J 0.50 J 5.0 U 5.8 3.1 J 1.9 J 3.4 J 0.65 J 0.7LMW PAH1 ug/Kg 16.01 15.45 17.31 14.15 91.04 8.72 11.96 14.09 14.11 14

HMW PAH1 ug/Kg 22.95 13.71 21.08 25 22.74 14.85 10.86 43.8 11.41 15PAH Sum1 ug/kg 38.96 29.16 38.39 39.15 113.78 23.57 22.82 57.89 25.52 29PESTICIDES2,4-DDD ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 2,4-DDE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 2,4-DDT ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 4,4-DDD ug/kg 5.0 Ui 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 4,4-DDE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 4,4-DDT ug/Kg 0.19 JP 5.0 U 5.0 U 5.0 U 5.0 U 5.0 Ui 5.0 U 5.0 U 5.0 U 5.0 ALDRIN ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ALPHA-BHC ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ALPHA-CHLORDANE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 BETA-BHC ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 CIS-NONACHLOR ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 DELTA-BHC ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 DIELDRIN ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ENDOSULFAN I ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ENDOSULFAN II ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ENDOSULFAN SULFATE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ENDRIN ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ENDRIN ALDEHYDE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 ENDRIN KETONE ug/kg 5.0 Ui 5.0 U 5.0 U 5.0 U 5.0 U 5.0 Ui 5.0 U 5.0 U 5.0 U 5.0 GAMMA-BHC (LINDANE) ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 GAMMA-CHLORDANE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 Ui 5.0 U 5.0 Ui 5.0 HEPTACHLOR ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 HEPTACHLOR EPOXIDE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 HEXACHLOROBENZENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 METHOXYCHLOR ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 MIREX ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 Oxychlordane ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 TOXAPHENE ug/kg 250 Ui 250 U 250 U 250 U 250 U 250 Ui 250 U 250 U 250 U 25TRANS-NONACHLOR ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 

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Table 4-3 CLLNG Phase 2 Chemistry and Grain Size Results

Sample ID C1U2 C2U2A C2U2B SB4U2 SB7U2 SB9U2 SB10U2 SB11U2 SB12U2 C3

Chemical Name Unit

PCBsPCB 8 (BZ) ug/kg 1.0 Ui 1.0 U 1.0 U 1.0 Ui 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 18 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 28 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 44 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 49 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 52 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 66 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 77 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 87 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 101 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 105 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 118 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 126 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 128 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 138 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 153 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 156 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 169 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 170 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 180 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 183 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 184 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 187 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 195 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 206 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB 209 (BZ) ug/kg 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 U 1.0 PCB Sum2 ug/kg 13 13 13 13 13 13 13 13 13 1

TPHRESIDUAL RANGE ORGANICS mg/kg 29 U 28 U 29 U 29 U 17 J 6.7 J 29 U 5.8 J 30 U 30 TPH AS DIESEL mg/kg 29 U 28 U 29 U 29 U 3.7 J 29 U 29 U 29 U 30 U 30 No values exceeded ER-L or ER-M

1PAH summation of Low Molecular Weight PAHs, High Molecular Weight PAHs, and Total PAHs; 1/2 RL used in the summation in non-detect cases.2PCB summation using 1/2 RL in non-detect cases.

Data Qualifiers:U: Undetected; parameter was not detected above the laboratory RL.*: The duplicate analysis was not within control limits. J: The result is an estimated concentration that is less than the RL but greater than or equal to the MDL.P: The GC confirmation criteria were exceeded. The RPD is greater than 40% between the two analytical results (25% for CLP Pesticides).i: The RL/MDL has been elevated, due to a chromatographic interference.N: MS/MSD exceed acceptance criteria.Z: The chromatoagraphic fingerprint does not resemble a petroleum product.

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Table 4-4 Casotte Landing sediment aluminum to metal regression coefficients (Phase 2) 

Parameter Correlation Coefficient (r) 

Antimony 

Arsenic 0.8244 

Beryllium 0.8709 

Cadmium 0.6271 

Chromium 0.8006 

Copper 0.9363 

Lead 0.9878 

Mercury 0.8821 

Nickel 0.7928 

Selenium 0.29351

Silver 0.0853 

Thallium 0.8806 

Zinc 0.8070 

1

 Selenium was not detected in 7 of 15 samples. 

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Table 4-5 Regional NOAA National Status and Trends comparison sites 

Decimal Degrees Northing/Eastings1

Site Date Sampled 

Longitude

(X) 

Latitude 

(Y) 

Longitude 

(X) 

Latitude 

(Y) 

North Point (Mobile Bay), MS 1984, 1985, 1986, 1988, 1990 -88.08000 30.29667 1222000.7402 290508.1230 

Pascagoula River, MS 1989 -88.56833 30.38000 1067811.8133 320124.6234 

Round Island, MS 1984, 1985, 1987 -88.61000 30.30667 1054725.5574 293425.7828 

Heron Bay, AL 1985, 1986, 1988 -89.47500 30.18333 781509.3733 249072.6853 

1

State Plane Mississippi East, NAD 83, US Feet 

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Table 4-6a Casotte Landing whole sediment bioassay findings – Americamysis bahia survival 

 

Replicate Survival at the End of 10 

Days Exposure (%) 

Mean 

Survival 

(%) 

Statistically lower than 

reference and different 

by more than 10%? 

Lab Control 100% 95% 95% 100% 95% 97% - 

Grand Bay 

Reference 95% 95% 95% 70% 95% 90% - 

Upper 

C1U2 1 95% 100% 90% 100% 90% 95% No 

C2U2 2 95% 95% 100% 100% 95% 97% No 

SB10U2 100% 85% 95% 95% 100% 95% No 

SB11U2 80% 90% 85% 95% 90% 88% No 

SB12U2 90% 100% 60% 95% 85% 86% No 

SB4U2 100% 100% 80% 90% 95% 93% No 

SB7U2 90% 95% 95% 95% 80% 91% No 

SB9U2 90% 75% 75% 85% 90% 83% No 

Lower 

C3L2 3 100% 90% 90% 95% 80% 91% No 

C4L2 4 90% 100% 95% 100% 100% 97% No 

SB10L2 85% 100% 100% 90% 70% 89% No 

SB12L2 90% 90% 75% 95% 15% 73% No 

SB7L2 95% 90% 85% 90% 100% 92% No 

Coastal 

SC123 95% 100% 100% 95% 100% 98% No 

1

 Composite SB1/SB2/SB3 upper layers 

2

 Composite SB5/SB6/SB8 upper layers 

3

 Composite SB1/SB2/SB3/SB4 lower layers 

4

 Composite SB5/SB6/SB8/SB9/SB11 lower layers 

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Table 4-6b Casotte Landing whole sediment bioassay findings – Leptocheirus plumulosus survival 

 Original Assay Additional Testing 

90% Batch No. - 

 - 1 94% 

 - 2 91% 

Lab Control 

 - 3 92% 

Original Assay Batch No. 

Collected 

Dec '05 

Collected Mar 

'06* 

Collected Mar 

'06** 

59% - - - - 

 - 1 31% 52% 87% 

 - 2 - 69% 81% 

Grand Bay 

Reference 

 - 3 - 81% 87% 

 Treatment Scenario 

 Original Assay Batch No. 

I 

(Archive) 

II 

(Acclimated) 

III 

(Acclimated/ 

Supplemented) 

Upper 

C1U2 1 67% 2 32% 25% 80% 

C2U2 2 46% 2 29% 30% 65% 

SB10U2 46% 1 39% 39% 87% 

SB11U2 52% 2 9% 38% 77% 

SB12U2 39% 3 44% 62% 78% 

SB4U2 42% 3 32% 16% 85% 

SB7U2 62% 3 43% 55% 85% 

SB9U2 45% 1 43% 53% 82% 

Lower 

C3L2 3 31% 2 20% 18% 62% 

C4L2 4 8% 2 9% 34% 67% 

SB10L2 14% 1 60% 53% 84% 

SB12L2 52% 3 29% 41% 86% 

SB7L2 21% 3 21% 20% 88% 

Coastal 

SC1,2,3 30% 1 8% 20% 82% 

1

 Composite SB1/SB2/SB3 upper layers 

2

 Composite SB5/SB6/SB8 upper layers 

3

 Composite SB1/SB2/SB3/SB4 lower layers 

4

 Composite SB5/SB6/SB8/SB9/SB11 lower layers 

* A new reference sample was collected March 21, 2006 and tested without acclimation 

**TetraMin was also added to the (unacclimated) reference to complement treatment III samples 

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Table 4-6c Casotte Landing whole sediment bioassay findings – Leptocheirus plumulosus survival – 

acclimated and supplemented treatment 

Batch 

No. 

Replicate Survival at the End of 10 Days 

Exposure (%) 

Mean 

Survival 

(%) 

Statistically lower than 

reference and different by 

more than 20%? 

1 95% 100% 85% 100% 90% 94% - 

Lab Control 2 85% 90% 90% 100% 90% 91% - 

3 95% 85% 95% 100% 85% 92% - 

1 75% 100% 85% 95% 80% 87% - 

2 85% 80% 85% 70% 85% 81% - Grand Bay 

Reference 5

3 85% 80% 90% 95% 85% 87% - 

Upper 

C1U2 1,7 2 80% 75% 70% 95% 80% 80% No 

C2U2 2,7 2 60% 65% 55% 70% 75% 65% No 

SB10U2 1 90% 95% 80% 90% 80% 87% No 

SB11U2F 7 2 80% 75% 70% 90% 70% 77% No 

SB12U2 6 3 80% 85% 80% 70% 75% 78% No 

SB4U2 3 90% 75% 75% 100% 85% 85% No 

SB7U2 3 90% 90% 75% 80% 90% 85% No 

SB9U2 1 80% 75% 85% 80% 90% 82% No 

Lower 

C3L2 3,7 2 65% 55% 50% 55% 85% 62% No 

C4L2 4,7 2 75% 65% 55% 75% 65% 67% No 

SB10L2 1 80% 95% 80% 75% 90% 84% No 

SB12L2 3 75% 90% 85% 90% 90% 86% No 

SB7L2 3 80% 85% 85% 100% 90% 88% No 

Coastal 

SC123 1 70% 80% 90% 85% 85% 82% No 

1

 Composite SB1/SB2/SB3 upper layers 

2

 Composite SB5/SB6/SB8 upper layers 

3

 Composite SB1/SB2/SB3/SB4 lower layers 

4

 Composite SB5/SB6/SB8/SB9/SB11 lower layers 

5

 Reference sample was collected March 21, 2006 and tested with Tetramin supplement but without 

acclimation. 

6

 Sample was not retained at termination of N. virens assay. Sediment was acclimated prior to testing. 

7

 Acclimated sample volume from N. virens assay was exhausted in initial Batch 2 assay that did not meet test 

acceptability criteria. Additional sediment was acclimated prior to Batch 2 re-test. 

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Table 4-7a Whole sediment bioassay statistical findings – Americamysis bahia

t-Test 

Project Site 

Data 

Normally 

Distributed* 

Data 

Variances 

Homogeneous* t-Value Critical t p-Value 

Significant

Difference

Project Site vs Grand Bay Reference 

Upper 

C1U2 1 NA NA NA NA NA NA 

C2U2 2 NA NA NA NA NA NA 

SB10U2 NA NA NA NA NA NA 

SB11U2 Yes Yes 0.61095 1.85955 0.2791 No 

SB12U2 Yes Yes 0.43372 1.85955 0.3380 No 

SB4U2 NA NA NA NA NA NA 

SB7U2 NA NA NA NA NA NA 

SB9U2 No Yes 20 - 0.0754 No 5

Lower 

C3L2 3 NA NA NA NA NA NA 

C4L2 4 NA NA NA NA NA NA 

SB10L2 Yes Yes 0.07287 1.85955 0.4718 No 

SB12L2 Yes Yes 1.16557 1.85955 0.1387 No 

SB7L2 NA NA NA NA NA NA 

Coastal 

SC123 NA NA NA NA NA NA 

*Normality evaluated using Shapiro Wilks analysis; homogeneity of variances evaluated using F-Test. 

1 Composite of SB1/SB2/SB3 upper layers 

2

 Composite of SB5/SB6/SB8 upper layers 

3

 Composite of SB1/SB2/SB3/SB4 lower layers 

4

 Composite of SB5/SB6/SB8/SB9/SB11 lower layers 

5

 Rank Sum test conducted when data not normally distributed 

NA: Not Applicable, station survivorship exceeded reference survivorship. 

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Table 4-7b Whole sediment bioassay statistical findings – Leptocheirus plumulosus – Acclimated and 

Supplemented Treatment

t- Test 

Project Site 

Batch 

No. 

Data 

Normally 

Distributed* 

Data 

Variances 

Homogeneous* t-Value Critical t p-Value 

Significant 

Difference 

Project Site vs Grand Bay Reference 

Upper 

C1U2 1 2 Yes Yes 0.20 1.85955 0.4247 No 

C2U2 2 2 Yes Yes 3.49 1.85955 0.0041 Yes 

SB10U2 1 Yes Yes 0.00 1.85955 0.5000 No 

SB11U2 2 Yes Yes 0.84 1.85955 0.2118 No 

SB12U2 3 Yes Yes 2.50 1.85955 0.0186 Yes 

SB4U2 3 Yes Yes 0.37 1.85955 0.3600 No 

SB7U2 3 Yes Yes 0.49 1.85955 0.3179 No 

SB9U2 1 Yes Yes 0.94 1.85955 0.1862 No 

Lower 

C3L2 3 2 No Yes 2.76 1.85955 0.0496 Yes5

C4L2 4 2 Yes Yes 2.95 1.85955 0.0092 Yes 

SB10L2 1 Yes Yes 0.51 1.85955 0.3129 No 

SB12L2 3 Yes Yes 0.26 1.85955 0.4014 No 

SB7L2 3 NA NA NA NA NA NA 

Coastal 

SC123 1 Yes Yes 0.87 1.85955 0.2047 No 

* Normality evaluated using Shapiro Wilks analysis; homogeneity of variances evaluated using F-Test 

1 Composite of SB1/SB2/SB3 upper layers 

2

 Composite of SB5/SB6/SB8 upper layers 

3

 Composite of SB1/SB2/SB3/SB4 lower layers 

4

 Composite of SB5/SB6/SB8/SB9/SB11 lower layers 

5

 Rank Sum test conducted when data not normally distributed. 

6

 Round two Reference indicates a non-normal distribution 

NA: Not Applicable, station survivorship exceeded reference survivorship.

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Table 4-8 CLLNG Elutriate Chemistry

Sample ID C1U2EA C2U2EA SB4U2EA SB7U2EA SB9U2EA SB9U2EB SB10U2EA SB11U2EA SB12U2EA 

Chemical Name Units

Dissolved MetalsANTIMONY ug/L 0.8 J 0.86 J 1.89 0.69 J 0.59 J 0.69 J 0.65 J 1.03 0.73 J 

ARSENIC ug/L 0.52 0.42 J 2.39 0.54 0.36 J 0.38 J 0.46 J 0.49 J 0.46 J BERYLLIUM ug/L 0.008 J 0.009 J 0.009 J 0.009 J 0.01 J 0.009 J 0.008 J 0.007 J 0.009 J CADMIUM ug/L 0.013 J 0.096 0.006 J 0.003 J 0.035 0.04 0.09 0.024 0.006 J CHROMIUM (Cr3+, Cr6+) ug/L 0.1 J 0.1 J 0.15 J 0.24 0.11 J 0.14 J 0.07 J 0.08 J 0.13 J 

COPPER ug/L 1.11 0.747 0.521 0.682 0.575 0.751 0.609 0.861 0.666 LEAD ug/L 0.296 * 0.085 * 0.042 * 0.063 * 0.086 * 0.088 * 0.096 * 0.07 * 0.079 * 

MERCURY ug/L 0.08 J 0.2 U 0.2 U 0.23 U 0.23 U 0.23 U 0.2 U 0.35 0.2 U NICKEL ug/L 1.71 3.27 0.9 1.18 3.85 2.12 3.07 1.82 1.47 SELENIUM ug/L 0.7 J 1.1 1 J 5.2 0.6 J 1 J 0.8 J 2.7 3.1 SILVER ug/L 0.02 U,*N 0.02 U,*N 0.02 U,*N 0.006 J,*N 0.02 U,*N 0.02 U,*N 0.02 U,*N 0.02 U,*N 0.02 U,*N 0THALLIUM ug/L 0.007 J 0.023 0.002 J 0.011 J 0.013 J 0.014 J 0.062 0.011 J 0.012 J ZINC ug/L 1.57 1.18 0.37 J 0.43 J 1.4 1.16 2.09 0.54 1.44 Total MetalsCHROMIUM (CR+6) ug/L 10 U 10 U 10 U 10 U 10 U 10 U 10 U 10 U 10 U 

MERCURY ug/L 0.2 U 0.2 U 0.2 U 0.23 U 0.23 U 0.23 U 0.09 J 0.4 0.2 U Nonmetals/OtherAMMONIA mg/L 1.05 0.82 2.9 3.05 1.19 1.23 1.45 1.72 1.63 CYANIDE mg/L 0.01 U 0.01 U 0.01 U 0.01 U 0.01 U 0.01 U 0.01 U 0.01 U 0.01 U 

NITRATE mg/L 0.09 J 0.11 J 0.09 J 0.06 J 0.08 J 0.08 J 0.06 J 0.09 J 0.08 J NITRATE + NITRITE mg/L 0.09 J 0.11 J 0.11 J 0.06 J 0.08 J 0.11 J 0.06 J 0.12 J 0.08 J NITRITE mg/L 0.01 U 0.01 U 0.02 J 0.2 U 0.2 U 0.03 J 0.01 U 0.03 J 0.2 U NITROGEN, KJELDAHL, TOTAL mg/L 1.3 1.2 3.1 4.1 1.8 1.7 2.7 2.3 1.8 PH Standard Units 7.38 7.29 8.62 8.45 7.3 7.31 7.41 7.03 7.17 REDOX mV Ag/AgCl 280 190 171 184 182 144 277 274 257 SULFIDE mg/L 0.05 U 0.05 U 0.014 J 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U 0.05 U BIOCHEMICAL OXYGEN DEMAND (BOD) mg/L 1.6 J 1.2 J 2.8 J 6 4 U 4 U 1.9 J 34 2.8 J CHEMICAL OXYGEN DEMAND (COD) mg/L 1980 1560 1250 1720 2040 1950 1700 1710 2090 PHOSPHOROUS, TOTAL ORTHOPHOSPHATE (AS P) mg/L 0.02 0.01 0.12 0.03 0.02 0.01 0.22 0.01 0.03 TOTAL ORGANIC CARBON mg/L 3 3.1 4 3.8 2.8 2.8 5 8.7 2.8 TOTAL SUSPENDED SOLIDS mg/L 5 U 5 U 5 7 6 7 5 U 7 7 DIESEL RANGE ORGANICS ug/L 30 J 71 Z 34 J 44 J 39 J 36 J 26 J 57 Z 35 J RESIDUAL RANGE ORGANICS ug/L 30 J 67 J 34 J 21 J 20 J 21 J 31 J 43 J 31 J 

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Table 4-8 CLLNG Elutriate Chemistry

Sample ID C1U2EA C2U2EA SB4U2EA SB7U2EA SB9U2EA SB9U2EB SB10U2EA SB11U2EA SB12U2EA 

Chemical Name UnitsPAHs1-METHYLNAPHTHALENE ug/L 0.02 U 0.0038 J 0.02 U 0.027 J 0.08 U 0.08 U 0.02 U 0.02 U 0.02 U 2-METHYLNAPHTHALENE ug/L 0.02 U 0.0036 J 0.02 U 0.011 J 0.08 U 0.08 U 0.02 U 0.02 U 0.02 U ACENAPHTHENE ug/L 0.0025 J 0.003 J 0.02 U 0.054 J 0.08 U 0.08 U 0.02 U 0.02 U 0.0032 J ACENAPHTHYLENE ug/L 0.0067 J 0.0081 J 0.0027 J 0.08 U 0.08 U 0.08 U 0.0082 J 0.003 J 0.0026 J ANTHRACENE ug/L 0.02 U 0.0015 J 0.02 U 0.014 J 0.08 U 0.08 U 0.02 U 0.02 U 0.02 U BENZO(A)ANTHRACENE ug/L 0.02 U 0.02 U 0.02 U 0.08 U 0.08 U 0.08 U 0.02 U 0.02 U 0.02 U BENZO(A)PYRENE ug/L 0.02 U 0.02 U 0.02 U 0.08 U 0.08 U 0.08 U 0.02 U 0.0023 J 0.02 U BENZO(B)FLUORANTHENE ug/L 0.02 U 0.02 U 0.02 U 0.08 U 0.08 U 0.08 U 0.02 U 0.0033 J 0.02 U BENZO(G,H,I)PERYLENE ug/L 0.02 U 0.0038 J 0.02 U 0.08 U 0.08 U 0.08 U 0.02 U 0.0074 J 0.02 U BENZO(K)FLUORANTHENE ug/L 0.02 U 0.02 U 0.02 U 0.08 U 0.08 U 0.08 U 0.02 U 0.0015 J 0.02 U CHRYSENE ug/L 0.02 U 0.02 U 0.02 U 0.08 U 0.08 U 0.08 U 0.02 U 0.0019 J 0.02 U DIBENZ(A,H)ANTHRACENE ug/L 0.02 U 0.0034 J 0.02 U 0.08 U 0.08 U 0.08 U 0.02 U 0.0055 J 0.02 U FLUORANTHENE ug/L 0.02 U 0.0034 J 0.0034 J 0.025 J 0.016 J 0.019 J 0.0025 J 0.0038 J 0.0041 J FLUORENE ug/L 0.02 U 0.0032 J 0.02 U 0.033 J 0.08 U 0.08 U 0.02 U 0.02 U 0.02 U INDENO(1,2,3-CD)PYRENE ug/L 0.02 U 0.0034 J 0.02 U 0.08 U 0.08 U 0.08 U 0.02 U 0.0098 J 0.02 U NAPHTHALENE ug/L 0.011 J 0.26 0.0095 J 0.029 J 0.023 J 0.022 J 0.013 J 0.0094 J 0.016 J PHENANTHRENE ug/L 0.007 J 0.0088 J 0.0053 J 0.074 J 0.022 J 0.022 J 0.0064 J 0.0048 J 0.0057 J PYRENE ug/L 0.02 U 0.0025 J 0.0029 J 0.02 J 0.011 J 0.014 J 0.02 U 0.0033 J 0.003 J LMW PAH1 ug/L 0.0672 0.292 0.0675 0.282 0.285 0.284 0.0776 0.0672 0.0675 

HMW PAH1 ug/L 0.1 0.0665 0.0863 0.365 0.347 0.353 0.0925 0.0488 0.0871 PAH Sum1 ug/L 0.1672 0.3585 0.1538 0.647 0.632 0.637 0.1701 0.116 0.1546 PCBsPCB 8 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 18 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 28 (BZ) ng/l 5 U 5 U 5 U 5.3 U 5 U 5 U 5 U 5 U 5 U PCB 44 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 49 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 52 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 66 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 77 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 87 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 101 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 Ui 4.9 Ui PCB 105 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 118 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 126 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 128 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 138 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 153 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 156 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 169 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 170 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 180 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 183 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 184 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 187 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 Ui 4.9 Ui PCB 195 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 206 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB 209 (BZ) ng/l 4.8 U 4.9 U 4.9 U 5.3 U 4.9 U 5 U 4.9 U 4.9 U 4.9 U PCB Sum2 ng/l 62.5 63.75 63.75 68.9 63.75 65 63.75 63.75 63.75 

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Table 4-8 CLLNG Elutriate Chemistry

Sample ID C1U2EA C2U2EA SB4U2EA SB7U2EA SB9U2EA SB9U2EB SB10U2EA SB11U2EA SB12U2EA 

Chemical Name UnitsPesticides2,4-DDD ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U 2,4-DDE ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U 2,4-DDT ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U 4,4-DDD ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U 4,4-DDE ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U 4,4-DDT ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U ALDRIN ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U ALPHA-BHC ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U ALPHA-CHLORDANE ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U BETA-BHC ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U CIS-NONACHLOR ug/L 0.01 U 0.01 U 0.01 Ui 0.01 Ui 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U DELTA-BHC ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U DIELDRIN ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U ENDOSULFAN I ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U ENDOSULFAN II ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U ENDOSULFAN SULFATE ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U ENDRIN ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U ENDRIN ALDEHYDE ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U ENDRIN KETONE ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U GAMMA-BHC (LINDANE) ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U GAMMA-CHLORDANE ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U HEPTACHLOR ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U HEPTACHLOR EPOXIDE ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U HEXACHLOROBENZENE ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U METHOXYCHLOR ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U MIREX ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U OXYCHLORDANE ug/L 0.01 Ui 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U TOXAPHENE ug/L 0.5 Ui 0.5 U 0.5 U 0.5 Ui 0.48 Ui 0.49 U 0.5 U 0.5 U 0.5 U TRANS-NONACHLOR ug/L 0.01 U 0.01 U 0.01 U 0.01 U 0.0096 U 0.0097 U 0.01 U 0.01 U 0.01 U 

1PAH summation of Low Molecular Weight PAHs, High Molecular Weight PAHs, and Total PAHs; 1/2 RL used in the summation in non-detect cases.2PCB summation using 1/2 RL in non-detect cases.3 Mississippi Sound reference site water results were used for dissolved metals because dissolved metals data were not available for the ODMDS.

Data Qualifiers:U: The compound was analyzed for, but was not detected ("Non-detect") at or above the RL/MDL.*: The duplicate analysis not within control limits. J: The result is an estimated concentration that is less than the RL but greater than or equal to the MDLi: The RL/MDL has been elevated, due to a chromatographic interference.N: MS/MSD exceed acceptance criteria.Z: The chromatographic fingerprint does not resemble a petroleum product.NA: Not analyzed

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Table 4-9 CLLNG Elutriate Chemistry Comparison to State and Federal Water Quality Criteria and Required Dilution Factors

Chemical Name Unit

Highest 

Result1 Federal WQC MS WQC

Minimum 

WQC ODMDS2 Dilution Factor3

Metals

ANTIMONY ug/L 1.89 N.S. N.S. N.S. 0.168 -

ARSENIC ug/L 2.39 36 36 36 1.3 <1

BERYLLIUM ug/L 0.01 N.S. N.S. N.S. 0.0085 -

CADMIUM ug/L 0.096 8.8 9.3 8.8 0.019 <1

CHROMIUM (Cr3+, Cr6+) ug/L 0.24 N.S. N.S. N.S. 0.09 -

CHROMIUM (HEXAVALENT) ug/L 5 * 50 50 50 0.09 4 <1

COPPER ug/L 1.11 3.1 3.1 3.1 0.595 <1

LEAD ug/L 0.296 8.1 8.1 8.1 0.015 <1

MERCURY ug/L 0.35 0.94 0.025 0.025 0.0006 13.3

MERCURY (TOTAL) ug/L 0.4 0.94 0.025 0.025 0.0012 15.8

NICKEL ug/L 21.8 8.2 18.51 8.2 0.53 1.8

SELENIUM ug/L 5.2 71 71 71 0.5 <1

SILVER 5 ug/L 0.0105* 1.9 1.9 1.9 0.01 <1

THALLIUM ug/L 0.062 N.S. N.S. N.S. 0.0121 -

ZINC ug/L 5.82 81 81 81 3.29 <1

Nonmetals/Other

AMMONIA mg/L 8.5 N.S. N.S. - 0.03 -

CYANIDE mg/L 0.005* 0.001 0.001 0.001 0.005 <1

NITRATE mg/L 0.11 N.S. N.S. N.S. 0.14 -

NITRATE + NITRITE mg/L 0.12 N.S. N.S. N.S. 0.14 -

NITRITE mg/L 0.1* N.S. N.S. N.S. 0.025 -

NITROGEN, KJELDAHL, TOTAL mg/L 7.5 N.S. N.S. N.S. 1.6 -

SULFIDE mg/L 0.024 2 N.S. 2 0.025 <1

BIOCHEMICAL OXYGEN DEMAND (BOD) mg/L 34 N.S. N.S. N.S. 2 -

CHEMICAL OXYGEN DEMAND (COD) mg/L 2090 N.S. N.S. N.S. 1230 -

PHOSPHOROUS, TOTAL ORTHOPHOSPHATE (AS P) mg/L 0.22 0.1 N.S. 0.1 0.02 1.5

TOTAL ORGANIC CARBON mg/L 8.7 N.S. N.S. N.S. -- -

TOTAL SUSPENDED SOLIDS mg/L 22 N.S. N.S. N.S. 6 -

DIESEL RANGE ORGANICS ug/L 94 N.S. N.S. N.S. 19 -

RESIDUAL RANGE ORGANICS ug/L 390 N.S. N.S. N.S. 25 -

PAHs 6

1-METHYLNAPHTHALENE ug/L 0.04* 300 N.S. 300 0.0086 <1

2-METHYLNAPHTHALENE ug/L 0.04* 300 N.S. 300 0.0095 <1

ACENAPHTHENE 7 ug/L 0.054 710 N.S. 710 0.01 <1

ACENAPHTHYLENE ug/L 0.04* 300 N.S. 300 0.01 <1

ANTHRACENE ug/L 0.04* 300 N.S. 300 0.01 <1

BENZO(A)ANTHRACENE ug/L 0.04* 300 N.S. 300 0.01 <1

BENZO(A)PYRENE ug/L 0.04* 300 N.S. 300 0.01 <1

BENZO(B)FLUORANTHENE ug/L 0.04* 300 N.S. 300 0.01 <1

BENZO(G,H,I)PERYLENE ug/L 0.04* 300 N.S. 300 0.01 <1

BENZO(K)FLUORANTHENE ug/L 0.04* 300 N.S. 300 0.01 <1

CHRYSENE ug/L 0.04* 300 N.S. 300 0.01 <1

DIBENZ(A,H)ANTHRACENE ug/L 0.04* 300 N.S. 300 0.01 <1

FLUORANTHENE 7 ug/L 0.04* 16 N.S. 16 0.01 <1

FLUORENE ug/L 0.04* 300 N.S. 300 0.01 <1

INDENO(1,2,3-CD)PYRENE ug/L 0.04* 300 N.S. 300 0.01 <1

NAPHTHALENE ug/L 0.26 2350 N.S. 2350 0.011 <1

PHENANTHRENE 8 ug/L 0.074 4.6 N.S. 4.6 0.01 <1

PYRENE ug/L 0.04* 300 N.S. 300 0.01 <1

PCBs

PCB 8 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 18 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 28 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 44 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 49 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 52 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 66 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 77 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 87 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 101 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 105 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 118 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 126 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

7/13/2006

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Table 4-9 CLLNG Elutriate Chemistry Comparison to State and Federal Water Quality Criteria and Required Dilution Factors

Chemical Name Unit

Highest 

Result1 Federal WQC MS WQC

Minimum 

WQC ODMDS2 Dilution Factor3

PCBs (con't)

PCB 128 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 138 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 153 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 156 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 169 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 170 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 180 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 183 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 184 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 187 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 195 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 206 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

PCB 209 (BZ) ng/L 2.65* N.S. N.S. N.S. 2.5 -

Total PCBs ng/L 68.9 0.03 N.S. 0.03 62.5 <1

Pesticides

2,4-DDD ug/L 0.005* N.S. N.S. N.S. 0.00485 -

2,4-DDE ug/L 0.005* N.S. N.S. N.S. 0.00485 -

2,4-DDT ug/L 0.005* N.S. N.S. N.S. 0.0012 -

4,4-DDD ug/L 0.005* N.S. N.S. N.S. 0.00485 -

4,4-DDE ug/L 0.005* N.S. N.S. N.S. 0.00485 -

4,4-DDT ug/L 0.005* 0.001 0.001 0.001 0.00485 <1

ALDRIN 5 ug/L 0.005* 1.3 1.3 1.3 0.00485 <1

ALPHA-BHC ug/L 0.005* N.S. N.S. N.S. 0.00485 -

ALPHA-CHLORDANE ug/L 0.005* N.S. N.S. N.S. 0.00485 -

GAMMA-CHLORDANE ug/L 0.005* N.S. N.S. N.S. 0.00485 -

OXYCHLORDANE ug/L 0.005* N.S. N.S. N.S. 0.00485 -

ALPHA + GAMMA + OXY-CHLORDANE ug/L 0.005* 0.004 0.004 0.004 0.00485 <1

BETA-BHC ug/L 0.005* N.S. N.S. N.S. 0.00485 -

CIS-NONACHLOR ug/L 0.005* N.S. N.S. N.S. 0.00485 -

DELTA-BHC ug/L 0.005* N.S. N.S. N.S. 0.00485 -

DIELDRIN ug/L 0.005* 0.0019 0.0019 0.0019 0.00485 <1

ENDOSULFAN I ug/L 0.005* 0.0087 N.S. 0.0087 0.00485 <1

ENDOSULFAN II ug/L 0.005* 0.0087 N.S. 0.0087 0.00485 <1

ENDOSULFAN I + ENDOSULFAN II ug/L 0.005* N.S. 0.0087 0.0087 0.00485 <1

ENDOSULFAN SULFATE ug/L 0.005* N.S. N.S. N.S. 0.00485 -

ENDRIN ug/L 0.005* 0.0023 0.0023 0.0023 0.00485 <1

ENDRIN ALDEHYDE ug/L 0.005* N.S. N.S. N.S. 0.00485 -

ENDRIN KETONE ug/L 0.005* N.S. N.S. N.S. 0.00485 -

GAMMA-BHC (LINDANE) 5 ug/L 0.005* 0.16 0.16 0.16 0.00485 <1

HEPTACHLOR ug/L 0.005* 0.0036 0.0036 0.0036 0.00485 <1

HEPTACHLOR EPOXIDE ug/L 0.005* 0.0036 N.S. 0.0036 0.00485 <1

HEXACHLOROBENZENE ug/L 0.005* N.S. N.S. N.S. 0.00485 -

METHOXYCHLOR ug/L 0.005* 0.03 N.S. 0.03 0.00485 <1

MIREX ug/L 0.005* 0.001 N.S. 0.001 0.00485 <1

TOXAPHENE ug/L 0.25* 0.0002 0.0002 0.0002 0.245 <1

TRANS-NONACHLOR ug/L 0.005* N.S. N.S. N.S. 0.00485 -

All metals are dissolved, unless otherwise noted. All organics are total.

* Value represents 1/2 RL

N.S. - Not Specified

1

 Highest station concentration

2

 Mississippi Sound results were used for dissolved metals because dissolved metals data were not available for the ODMDS.

3 The dilution factor calculation formula is provided in Section 2.3.4

4 Hexavalent chromium data were not available for ODMDS, so chromium (Cr3+, Cr6+) result was used instead. 5 Chronic WQC were not available. Acute WQC was used instead.

6 Chronic WQC were not available for PAHs. Acute Lowest Observable Effect Levels (Buchman, 1999) were used instead, unless otherwise noted. 7

 Chronic WQC were not available. Chronic Lowest Observable Effect Levels (Buchman, 1999) was used instead.

8 Chronic WQC were not available. Proposed chronic WQC was used instead.

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Q:\mw97\Projects\01231021\0049\Sec_4 Tables.doc July 2006

Table 4-10a Standard SPP bioassay findings – Americamysis bahia percent survival results 

Percent Survival of A. bahia after 96 Hours Exposure 

Treatment SC123 8 C1U2 1,5 C2U2 2, 5 SB10U2 5 SB11U2 6 SB12U2 6 SB4U2 6

Diluent 96% 94% 94% 94% 98% 98% 98% 

Lab Control 98% 98% 98% 98% 98% 98% 98% 

1% SPP 98% 100% 96% 98% 98% 94% 98% 

10% SPP 100% 98% 98% 98% 96% 98% 96% 

50% SPP 94% 98% 98% 98% 96% 96% 100% 

100% SPP 98% 98% 100% 100% 98% 94% 100% 

LC-50 >100 >100 >100 >100 >100 >100 >100 

 

Treatment SB7U2 7 SB9U2 7 C3L2 3,7 C4L2 4,7 SB10L2 8 SB12L2 8 SB7L2 8

Diluent 98% 98% 98% 98% 96% 96% 96% 

Lab Control 92% 92% 92% 92% 98% 98% 98% 

1% SPP 96% 96% 96% 98% 96% 98% 98% 

10% SPP 94% 92% 98% 100% 94% 96% 92% 

50% SPP 98% 94% 94% 100% 96% 100% 96% 

100% SPP 94% 92% 84% 86% 96% 76% 48% 

LC-50 >100 >100 >100 >100 >100 >100 99.2 

1

 Composite of SB1/SB2/SB3 upper layers 

2

 Composite of SB5/SB6/SB8 upper layers 

3

 Composite of SB1/SB2/SB3/SB4 lower layers 

4

 Composite of SB5/SB6/SB8/SB9/SB11 lower layers 

5

 Testing started on 2/1/06 

6

 Testing started on 2/2/06 

7

 Testing started on 2/6/06 

8

 Testing started on 2/8/06

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Table 4-10b Standard SPP bioassay findings – Menidia beryllina percent survival results 

Percent Survival of M. beryllina after 96 Hours Exposure 

Treatment SC123 8 C1U2 1,5 C2U2 2,5 SB10U2 5 SB11U2 6 SB12U2 6 SB4U2 6

Diluent 90% 98% 98% 98% 98% 98% 98% 

Lab Control 98% 100% 100% 100% 100% 100% 100% 

1% SPP 92% 100% 100% 100% 98% 92% 96% 

10% SPP 94% 100% 100% 100% 100% 100% 98% 

50% SPP 94% 100% 100% 98% 100% 96% 92% 

100% SPP 84% 100% 96% 100% 98% 90% 96% 

LC-50 >100 >100 >100 >100 >100 >100 >100 

 

Treatment SB7U2 7 SB9U2 7 C3L2 3,7 C4L2 4,7 SB10L2 8 SB12L2 8 SB7L2 8

Diluent 98% 98% 98% 98% 90% 90% 90% 

Lab Control 98% 98% 98% 98% 98% 98% 98% 

1% SPP 96% 94% 88% 98% 88% 96% 96% 

10% SPP 94% 98% 98% 100% 96% 98% 96% 

50% SPP 96% 100% 94% 96% 98% 94% 90% 

100% SPP 100% 100% 98% 100% 96% 92% 100% 

LC-50 >100 >100 >100 >100 >100 >100 >100 

1

 Composite of SB1/SB2/SB3 upper layers 

2

 Composite of SB5/SB6/SB8 upper layers 

3

 Composite of SB1/SB2/SB3/SB4 lower layers 

4

 Composite of SB5/SB6/SB8/SB9/SB11 lower layers 

5

 Testing started on 2/1/06 

6

 Testing started on 2/2/06 

7

 Testing started on 2/6/06 

8

 Testing started on 2/8/06

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Table 4-10c Standard SPP bioassay findings – Arbacia punctulata percent survival and percent 

normal development results 

Percent Survival of A. punctulata 

Treatment SC123 7 C1U2 1,5 C2U2 2,5 SB10U2 5 SB11U2 7 SB12U2 7 SB4U2 7 

Diluent 81% 95% 95% 95% 81% 81% 81% 

Lab Control 94% 93% 93% 93% 94% 94% 94% 

1% SPP 86% 95% 96% 94% 93% 97% 97% 

10% SPP 94% 96% 88% 92% 95% 90% 89% 

50% SPP 81% 95% 86% 93% 94% 95% 86% 

100% SPP 77% 98% 71% 83% 97% 90% 22% 

LC-50 >100 >100 >100 >100 >100 >100 89.0 

Treatment SB7U2 6 SB9U2 6 C3L2 3,6 C4L2 4,6 SB10L2 7 SB12L2 7 SB7L2 7

Diluent 65% 65% 65% 65% 81% 81% 81% 

Lab Control 93% 93% 93% 93% 94% 94% 94% 

1% SPP 85% 66% 68% 78% 91% 93% 85% 

10% SPP 74% 69% 70% 77% 82% 90% 84% 

50% SPP 68% 76% 86% 77% 86% 97% 84% 

100% SPP 4% 78% 90% 80% 95% 95% 98% 

LC-50 67.6 >100 >100 >100 >100 >100 >100 

Percent Normal Development of A. punctulata 

Treatment SC123 7 C1U2 1,5 C2U2 2,5 SB10U2 5 SB11U2 7 SB12U2 7 SB4U2 7 

Diluent 76% 94% 94% 94% 76% 76% 76% 

Lab Control 92% 92% 92% 92% 92% 92% 92% 

1% SPP 86% 95% 93% 94% 93% 97% 99% 

10% SPP 94% 96% 86% 91% 95% 90% 92% 

50% SPP 21% 93% 81% 92% 94% 95% 85% 

100% SPP 0% 94% 66% 73% 94% 60% 0% 

EC-50 50.8 >100 >100 >100 >100 >100 68.4 

Treatment SB7U2 6 SB9U2 6 C3L2 3,6 C4L2 4,6 SB10L2 7 SB12L2 7 SB7L2 7

Diluent 62% 62% 62% 62% 76% 76% 76% 

Lab Control 90% 90% 90% 90% 92% 92% 92% 

1% SPP 84% 64% 67% 77% 92% 93% 85% 

10% SPP 71% 68% 69% 76% 82% 90% 84% 

50% SPP 64% 75% 84% 76% 86% 97% 80% 

100% SPP 0% 75% 87% 79% 78% 88% 75% 

EC-50 60.1 >100 >100 >100 >100 >100 >100 

1

 Composite of SB1/SB2/SB3 upper layers 

2

 Composite of SB5/SB6/SB8 upper layers 

3

 Composite of SB1/SB2/SB3/SB4 lower layers 

4

 Composite of SB5/SB6/SB8/SB9/SB11 lower layers 

5

 Testing started on 2/1/06 

6

 Testing started on 2/6/06 

7

 Testing started on 2/11/06

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Table 4-11 Median lethal concentration calculation summary 

 

Ab LC50

(%)

Mb LC50

(%)

Ap LC50

(%)

Ap EC50

(%)

Upper 

C1U2 1 >100 >100 >100 >100 

C2U2 2 >100 >100 >100 >100 

SB10U2 >100 >100 >100 >100 

SB11U2 >100 >100 >100 >100 

SB12U2 >100 >100 >100 >100 

SB4U2 >100 >100 89 68.4 

SB7U2 >100 >100 67.6 60.1 

SB9U2 >100 >100 >100 >100 

Lower 

C3L2 3 >100 >100 >100 >100 

C4L2 4 >100 >100 >100 >100 

SB10L2 >100 >100 >100 >100 

SB12L2 >100 >100 >100 >100 

SB7L2 99.2 >100 >100 >100 

Coastal 

SC123 >100 >100 >100 50.8 

Ab: Americamysis bahia – survival 

Mb: Menidia beryllina – survival 

Ap: Arbacia punctulata - survival and development 

1

 Composite SB1/SB2/SB3 upper layers 

2

 Composite SB5/SB6/SB8 upper layers 

3

 Composite SB1/SB2/SB3/SB4 lower layers 

4

 Composite SB5/SB6/SB8/SB9/SB11 lower layers 

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Table 4-12a Standard SPP bioassay supporting statistics – Americamysis bahia percent survival 

results 

t- Test 

Project Site 

Data 

Normally 

Distributed* 

Data 

Variances 

Homogeneous* t-Value Critical t p-Value 

Significant

Difference

Project Site vs ODMDS Diluent Control 

Upper 

C1U2 1 NA NA NA NA NA NA 

C2U2 2 NA NA NA NA NA NA 

SB10U2 NA NA NA NA NA NA 

SB11U2 NA NA NA NA NA NA 

SB12U2 Yes Yes 1.265 1.860 0.2415 No 

SB4U2 NA NA NA NA NA NA 

SB7U2 Yes Yes 0.876 1.860 0.4068 No 

SB9U2 Yes Yes 2.121 1.860 0.0667 Yes 

Lower 

C3L2 3 Yes Yes 3.056 1.860 0.0157 Yes 

C4L2 4 No Yes 19.5 - - No 5

SB10L2 NA NA NA NA NA NA 

SB12L2 Yes Yes 2.283 1.860 0.0518 Yes 

SB7L2 Yes Yes 5.735 1.860 0.0004 Yes 

Coastal 

SC123 NA NA NA NA NA NA 

* Normality evaluated using Shapiro Wilks analysis; homogeneity of variances evaluated using F-Test. 

1

 Composite of SB1/SB2/SB3 upper layers 

2

 Composite of SB5/SB6/SB8 upper layers 

3

 Composite of SB1/SB2/SB3/SB4 lower layers 

4

 Composite of SB5/SB6/SB8/SB9/SB11 lower layers 

5 Rank Sum test conducted when data not normally distributed 

 NA: Not Applicable, station survivorship exceeded reference survivorship 

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Table 4-12b Standard SPP bioassay supporting statistics – Menidia beryllina percent survival results 

t- Test 

Project Site 

Data 

Normally 

Distributed* 

Data 

Variances 

Homogeneous* t-Value Critical t p-Value 

Significant

Difference

Project Site vs ODMDS Diluent Control 

Upper 

C1U2 1 NA** NA NA NA NA NA 

C2U2 2 No Yes 27 - - No 5

SB10U2 NA NA NA NA NA NA 

SB11U2 NA NA NA NA NA NA 

SB12U2 Yes Yes 2.166 1.860 0.0622 Yes 

SB4U2 No Yes 25 - - No 5

SB7U2 NA NA NA NA NA NA 

SB9U2 NA NA NA NA NA NA 

Lower 

C3L2 3 NA NA NA NA NA NA 

C4L2 4 NA NA NA NA NA NA 

SB10L2 NA NA NA NA NA NA 

SB12L2 NA NA NA NA NA NA 

SB7L2 NA NA NA NA NA NA 

Coastal 

SC123 Yes No 1.529 2.132 0.1647 No 

* Normality evaluated using Shapiro Wilks analysis; homogeneity of variances evaluated using F-Test. 

1

 Composite of SB1/SB2/SB3 upper layers 

2

 Composite of SB5/SB6/SB8 upper layers 

3

 Composite of SB1/SB2/SB3/SB4 lower layers 

4

 Composite of SB5/SB6/SB8/SB9/SB11 lower layers 

5 Rank Sum test conducted when data not normally distributed 

 NA: Not Applicable, station survivorship exceeded reference survivorship 

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Table 4-12c Standard SPP bioassay supporting statistics – Arbacia punctulata percent survival 

results 

t- Test 

Project Site 

Data 

Normally 

Distributed* 

Data 

Variances 

Homogeneous* t-Value Critical t p-Value 

Significant

Difference

Project Site vs ODMDS Diluent Control 

Upper 

C1U2 1 NA NA NA NA NA NA 

C2U2 2 Yes Yes 7.323 1.860 8.2E-05 Yes 

SB10U2 Yes Yes 4.310 1.860 0.002581 Yes 

SB11U2 NA NA NA NA NA NA 

SB12U2 NA NA NA NA NA NA 

SB4U2 Yes Yes 15.113 1.860 3.6E-07 Yes 

SB7U2 Yes Yes 26.361 1.860 4.6E-09 Yes 

SB9U2 NA NA NA NA NA NA 

Lower 

C3L2 3 NA NA NA NA NA NA 

C4L2 4 NA NA NA NA NA NA 

SB10L2 NA NA NA NA NA NA 

SB12L2 NA NA NA NA NA NA 

SB7L2 NA NA NA NA NA NA 

Coastal 

SC123 Yes Yes 1.566 1.860 0.1560 No 

* Normality evaluated using Shapiro Wilks analysis; homogeneity of variances evaluated using F-Test. 

1

 Composite of SB1/SB2/SB3 upper layers 

2

 Composite of SB5/SB6/SB8 upper layers 

3

 Composite of SB1/SB2/SB3/SB4 lower layers 

4

 Composite of SB5/SB6/SB8/SB9/SB11 lower layers 

 NA: Not Applicable, station survivorship exceeded reference survivorship 

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Table 4-13 Agency recommended tissue analysis scope 

Parameters Stations1

% Lipids, % Solids 

SB7U, SB7L, SB10L, SC123, Grand Bay 

Reference 

Metals

 Antimony 

 Arsenic 

 Beryllium 

 Cadmium 

 Chromium (Total) 

 Copper SB7L, SB10L, SC123, Grand Bay Reference 

 Lead 

 Mercury 

 Nickel 

 Selenium 

 Silver 

 Thallium 

 Zinc 

PAHs

 1-Methylnaphthalene 

 2-Methylnaphthalene 

 Acenaphthene 

 Acenaphthylene 

 Anthracene 

 Benzo(a)anthracene 

 Benzo(a)pyrene 

 Benzo(b)fluoranthene SB7U, Grand Bay Reference 

 Benzo(g,h,i)perylene 

 Benzo(k)fluoranthene 

 Chrysene 

 Dibenz(a,h)anthracene 

 Fluoranthene 

 Fluorene 

 Indeno(1,2,3-cd)pyrene 

 Naphthalene 

 Phenanthrene 

 Pyrene 

1

 5 replicates per station per tissue type 

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Table 4-14 Casotte Landing Station SB7U biota to sediment accumulation factors1

 Macoma Nereis 

 Reference SB7U2 Reference SB7U2 

1-Methylnaphthalene 0.60 0.01 0.76 0.01 

2-Methylnaphthalene 0.39 0.01 0.32 0.01 

Acenaphthene 0.16 0.005 ND 0.004 

Anthracene 0.16 0.11 ND ND 

Benzo(a)anthracene 0.22 0.13 ND 0.39 

Benzo(a)pyrene 0.43 0.39 0.30 0.28 

Benzo(b)fluoranthene 0.31 0.13 ND 0.61 

Benzo(g,h,i)perylene 1.30 ND2 ND 0.75 

Benzo(k)fluoranthene 0.58 0.09 ND 0.70 

Chrysene 0.18 0.22 ND 0.37 

Fluoranthene 0.40 0.42 0.13 0.07 

Fluorene 0.13 0.02 0.11 0.01 

Indeno(1,2,3-CD)pyrene ND ND ND 0.78 

Naphthalene 0.23 0.03 0.18 0.03 

Phenanthrene 0.80 0.13 0.33 0.02 

Pyrene 0.17 0.26 0.21 0.05 

1

BSAFs have been calculated for parameters detected in at least three tissue replicates. 

Italicized values were undetected in the sediment, and 1/2 RL was substituted for the 

calculation. Wet weight tissue concentrations were used. 

2

ND - Analyte was detected in less than three tissue replicates. 

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Table 4-15a 28-day bioassay survival – Macoma nasuta percent survival results 

Project Site 

Percent Survival After 28 Days 

Exposure* 

Mean 

Percent 

Survival 

Laboratory Control 100% 90% 100% 90% 5 97% 95% 

Grand Bay Reference 87% 73% 100% 100% 100% 92% 

Upper 

C1U 1 87% 100% 90% 83% 90% 90% 

C2U 2 90% 97% 90% 93% 97% 93% 

SB10U2 87% 90% 90% 87% 97% 90% 

SB11U2 77% 6 93% 97% 87% 90% 89% 

SB12U2 93% 100% 100% 87% 93% 95% 

SB4U2 100% 94% 90% 100% 97% 96% 

SB7U2 93% 100% 97% 93% 97% 96% 

SB9U2 90% 87% 97% 90% 90% 91% 

Lower 

C3L 3 90% 83% 87% 83% 90% 87% 

C4L 4 93% 97% 81% 90% 77% 88% 

SB10L2 83% 100% 83% 90% 87% 89% 

SB12L2 97% 90% 83% 83% 93% 89% 

SB7L2 87% 90% 97% 87% 90% 90% 

Coastal 

SC123 90% 80% 93% 93% 80% 87% 

* n = 30 organisms per replicate 

1

 Composite of SB1/SB2/SB3 upper layers 

2

 Composite of SB5/SB6/SB8 upper layers 

3

 Composite of SB1/SB2/SB3/SB4 lower layers 

4

 Composite of SB5/SB6/SB8/SB9/SB11 lower layers 

5

 Only 20 organisms were added to this replicate (versus 30 specified) 

6

 An excess of organisms were added to this replicate at test initiation. Percent 

survival is based on 60 original organisms (total of surviving and deceased 

organisms) 

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Table 4-15b 28-day bioassay survival – Nereis virens percent survival results 

Project Site 

Percent Survival After 28 Days 

Exposure* 

Mean 

Percent 

Survival 

Laboratory Control 90% 90% 100% 100% 85% 93% 

Grand Bay Reference 100% 100% 100% 75% 100% 95% 

Upper 

C1U 1 100% 90% 80% 80% 75% 85% 

C2U 2 85% 80% 90% 100% 80% 87% 

SB10U2 75% 90% 95% 85% 70% 83% 

SB11U2 90% 85% 85% 90% 70% 84% 

SB12U2 70% 100% 95% 85% 90% 88% 

SB4U2 90% 85% 100% 90% 95% 92% 

SB7U2 90% 75% 100% 60% 100% 85% 

SB9U2 85% 95% 95% 70% 100% 89% 

Lower 

C3L 3 80% 65% 60% 85% 85% 75% 

C4L 4 90% 100% 90% 80% 75% 87% 

SB10L2 100% 95% 100% 100% 80% 95% 

SB12L2 80% 80% 100% 100% 75% 87% 

SB7L2 65% 100% 65% 80% 65% 75% 

Coastal 

SC123 70% 100% 85% 95% 100% 90% 

* n = 30 organisms per replicate 

1

 Composite of SB1/SB2/SB3 upper layers 

2

 Composite of SB5/SB6/SB8 upper layers 

3

 Composite of SB1/SB2/SB3/SB4 lower layers 

4

 Composite of SB5/SB6/SB8/SB9/SB11 lower layers 

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Table 4-16 Tissue Chemistry Results - Macoma nasuta (Wet Weight)

Sample ID

Replicate 123451234

Chemical Name UnitTOTAL LIPIDS PERCENT 0.5 0.52 0.59 0.68 0.64 0.63 0.64 0.73 0.68 TOTAL SOLIDS PERCENT 13 13.2 12.9 15.8 15 15.7 14.3 16.6 15.5 ANTIMONY mg/kg 0.015 0.019 0.016 0.021 0.017 0.012 0.013 0.014 0.013 ARSENIC mg/kg 3.26 3.77 3.35 4.07 3.62 3.75 3.52 3.41 3.55 BERYLLIUM mg/kg 0.0007 J 0.0012 J 0.0008 J 0.0013 J 0.001 J 0.0063 0.0064 0.0086 0.0057 CADMIUM mg/kg 0.0308 0.0327 0.0288 0.0376 0.0407 0.0322 0.032 0.0286 0.042 CHROMIUM mg/kg 0.12 0.23 0.18 0.26 0.16 0.36 0.34 0.42 0.37 COPPER mg/kg 1.53 1.71 1.49 1.78 1.94 2.78 1.87 2.42 1.93 LEAD mg/kg 0.076 0.106 0.083 0.095 0.12 0.241 0.198 0.269 0.198 MERCURY mg/kg 0.002 J 0.003 0.003 0.003 J 0.004 0.004 0.004 0.006 0.004 NICKEL mg/kg 0.405 0.42 0.397 0.584 0.434 0.557 0.443 0.449 0.561 SELENIUM mg/kg 0.18 0.25 0.21 0.2 0.27 0.29 0.27 0.24 0.26 SILVER mg/kg 0.0507 0.07 0.0547 0.0839 0.0863 0.108 0.0631 0.0585 0.0858 THALLIUM mg/kg 0.0011 J 0.0013 J 0.0011 J 0.0014 J 0.0014 J 0.0021 J 0.002 J 0.0026 J 0.0018 J ZINC mg/kg 11.8 12.5 12.3 17 13.8 14.5 16 15.6 16.1 1-METHYLNAPHTHALENE ug/Kg 0.66 J 0.67 J 0.65 J 0.74 J 0.60 J 0.58 J 0.57 J 0.61 J 0.66 J 2-METHYLNAPHTHALENE ug/Kg 0.67 J 0.69 J 0.59 J 0.73 J 0.66 J 0.69 J 0.61 J 0.65 J 0.74 J ACENAPHTHENE ug/Kg 0.18 J 0.12 J 5.0 U 0.15 J 0.14 J 0.19 J 0.16 J 0.38 J 0.17 J ACENAPHTHYLENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U ANTHRACENE ug/Kg 0.20 J 0.16 J 0.15 J 0.19 J 0.20 J 0.18 J 0.14 J 0.12 J 0.19 J BENZO(A)ANTHRACENE ug/Kg 0.25 J 0.22 J 0.17 J 0.20 J 0.30 J 0.15 J 5.0 U 0.18 J 0.16 J BENZO(A)PYRENE ug/Kg 0.62 J 0.52 J 0.64 J 0.53 J 0.66 J 0.81 J 0.82 J 0.85 J 0.99 J BENZO(B)FLUORANTHENE ug/kg 0.24 J 5.0 U 0.24 J 5.0 U 0.26 J 5.0 U 0.25 J 0.28 J 0.33 J BENZO(G,H,I)PERYLENE ug/kg 0.17 J 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U BENZO(K)FLUORANTHENE ug/kg 0.15 J 5.0 U 0.17 J 5.0 U 0.15 J 5.0 U 0.18 J 0.21 J 0.19 J CHRYSENE ug/Kg 0.48 J 0.42 J 0.43 J 0.53 J 0.52 J 0.43 J 0.42 J 0.42 J 0.51 J DIBENZ(A,H)ANTHRACENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U FLUORANTHENE ug/Kg 2.0 J 1.8 J 1.9 J 2.3 J 2.4 J 2.2 J 1.7 J 2.1 J 2.8 J FLUORENE ug/Kg 0.44 J 0.36 J 0.39 J 0.45 J 0.41 J 0.55 J 0.49 J 0.51 J 0.66 J INDENO(1,2,3-CD)PYRENE ug/kg 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U NAPHTHALENE ug/Kg 0.77 J 0.84 J 0.84 J 0.96 J 0.83 J 1.1 J 1.0 J 0.97 J 1.1 J PHENANTHRENE ug/Kg 1.2 J 1.2 J 1.1 J 1.6 J 1.4 J 3.1 J 2.6 J 2.7 J 4.2 J PYRENE ug/Kg 1.0 J 0.88 J 0.95 J 1.1 J 1.2 J 1.1 J 0.96 J 0.94 J 1.4 J 

Unexposed Grand Bay Reference 

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Table 4-16 Tissue Chemistry Results - Macoma nasuta (Wet Weight)

Sample ID

Replicate 123451234

Chemical Name UnitTOTAL LIPIDS PERCENT 0.59 0.58 0.54 0.6 0.65 0.62 0.59 0.59 0.56 TOTAL SOLIDS PERCENT 14.2 15.7 13.8 13.9 14.3 14.6 16.3 14.4 14.8 ANTIMONY mg/kg 0.013 0.016 0.015 0.014 0.018 0.02 0.014 0.017 0.016 ARSENIC mg/kg 2.89 3.12 3.37 3.42 3.42 3.3 3.04 3.15 3.43 BERYLLIUM mg/kg 0.0058 0.0038 0.0045 0.0048 0.0039 0.004 0.0043 0.0031 0.0033 CADMIUM mg/kg 0.0303 0.0354 0.0362 0.0359 0.0345 0.0473 0.0357 0.036 0.0366 CHROMIUM mg/kg 0.26 0.22 0.24 0.31 0.29 0.24 0.32 0.22 0.15 COPPER mg/kg 2.29 2.12 1.85 2.03 2.12 2 1.68 2.16 2.11 LEAD mg/kg 0.145 0.14 0.149 0.147 0.136 0.157 0.145 0.133 0.139 MERCURY mg/kg 0.004 0.004 0.003 0.004 0.004 0.003 0.004 0.004 0.004 NICKEL mg/kg 0.423 0.452 0.408 0.393 0.424 0.452 0.748 0.457 0.509 SELENIUM mg/kg 0.25 0.26 0.25 0.22 0.26 0.2 0.22 0.22 0.18 SILVER mg/kg 0.0531 0.0454 0.0732 0.0703 0.0626 0.0523 0.0528 0.0736 0.061 THALLIUM mg/kg 0.0017 J 0.0012 J 0.0014 J 0.0017 J 0.0014 J 0.0018 J 0.0015 J 0.0011 J 0.0017 J ZINC mg/kg 12 14.1 13.5 16.4 13.7 18 13.5 14.3 13.2 1-METHYLNAPHTHALENE ug/Kg NA NA NA NA NA NA NA NA NA 2-METHYLNAPHTHALENE ug/Kg NA NA NA NA NA NA NA NA NA ACENAPHTHENE ug/Kg NA NA NA NA NA NA NA NA NA ACENAPHTHYLENE ug/kg NA NA NA NA NA NA NA NA NA ANTHRACENE ug/Kg NA NA NA NA NA NA NA NA NA BENZO(A)ANTHRACENE ug/Kg NA NA NA NA NA NA NA NA NA BENZO(A)PYRENE ug/Kg NA NA NA NA NA NA NA NA NA BENZO(B)FLUORANTHENE ug/kg NA NA NA NA NA NA NA NA NA BENZO(G,H,I)PERYLENE ug/kg NA NA NA NA NA NA NA NA NA BENZO(K)FLUORANTHENE ug/kg NA NA NA NA NA NA NA NA NA CHRYSENE ug/Kg NA NA NA NA NA NA NA NA NA DIBENZ(A,H)ANTHRACENE ug/kg NA NA NA NA NA NA NA NA NA FLUORANTHENE ug/Kg NA NA NA NA NA NA NA NA NA FLUORENE ug/Kg NA NA NA NA NA NA NA NA NA INDENO(1,2,3-CD)PYRENE ug/kg NA NA NA NA NA NA NA NA NA NAPHTHALENE ug/Kg NA NA NA NA NA NA NA NA NA PHENANTHRENE ug/Kg NA NA NA NA NA NA NA NA NA PYRENE ug/Kg NA NA NA NA NA NA NA NA NA Data Qualifiers:U: Undetected; parameter was not detected above the laboratory RL.J: The result is an estimated concentration that is less than the RL but greater than or equal to the MDL.NA: Not analyzed per agency recommendation.

Station SB7L Station SB10L 

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Sample ID

Replicate 123451234

Chemical Name UnitTOTAL LIPIDS PERCENT 0.83 0.86 0.9 0.9 0.97 0.65 0.7 0.61 0.67 TOTAL SOLIDS PERCENT 17.5 17.9 17.6 17.8 17.5 11.9 12.9 12.4 13.2 ANTIMONY mg/kg 0.002 J 0.004 J 0.002 J 0.002 J 0.004 J 0.002 J 0.003 J 0.003 J 0.003 J ARSENIC mg/kg 2.51 2.45 2.57 2.67 2.39 1.65 2.02 1.8 1.98 BERYLLIUM mg/kg 0.0226 0.02 0.0232 0.0269 0.0206 0.0009 J 0.0026 U 0.003 0.0011 J CADMIUM mg/kg 0.0517 0.0501 0.0528 0.0539 0.0485 0.0399 0.0395 0.0407 0.038 CHROMIUM mg/kg 1.32 1.32 1.33 1.35 1.29 0.09 0.12 0.25 0.12 COPPER mg/kg 2.22 2.19 2.28 2.27 2.12 0.981 1.16 1.04 1.11 LEAD mg/kg 0.437 0.447 0.447 0.457 0.411 0.078 0.091 0.124 0.105 MERCURY mg/kg 0.046 0.047 0.046 0.042 0.045 0.029 0.028 0.029 0.026 NICKEL mg/kg 0.701 0.688 0.727 0.717 0.682 0.16 0.218 0.287 0.257 SELENIUM mg/kg 0.18 0.22 0.24 0.18 0.18 J 0.16 0.16 0.17 0.11 J SILVER mg/kg 0.0378 0.038 0.0377 0.0368 0.0356 0.0167 0.0193 0.022 0.0167 THALLIUM mg/kg 0.0059 0.0061 0.0062 0.006 0.0055 0.0024 U 0.0005 J 0.0012 J 0.0004 J ZINC mg/kg 41.6 N 34.1 N 39.9 N 74.4 N 62.7 N 20.4 N 33.7 N 37.5 N 63.3 N 1-METHYLNAPHTHALENE ug/Kg 0.98 J 1.0 J 1.0 J 0.93 J 1.0 J 0.79 J 0.82 J 0.45 J 0.90 J 2-METHYLNAPHTHALENE ug/Kg 1.0 J 0.72 J 0.83 J 0.69 J 0.82 J 0.57 J 0.62 J 0.28 J 0.65 J ACENAPHTHENE ug/kg 5.1 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 0.18 J 5.0 U ACENAPHTHYLENE ug/kg 5.1 U 0.78 J 5.0 U 0.72 J 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U ANTHRACENE ug/kg 0.54 J 0.36 J 0.29 J 5.0 U 0.40 J 5.0 U 5.0 U 0.10 J 5.0 U BENZO(A)ANTHRACENE ug/kg 1.3 J 1.1 J 0.83 J 1.4 J 1.3 J 5.0 U 5.0 U 5.0 U 5.0 U BENZO(A)PYRENE ug/Kg 2.4 J 2.3 J 1.9 J 2.1 J 2.4 J 0.68 J 0.55 J 0.67 J 0.62 J BENZO(B)FLUORANTHENE ug/kg 1.6 J 1.3 J 1.2 J 1.5 J 1.6 J 5.0 U 5.0 U 5.0 U 5.0 U BENZO(G,H,I)PERYLENE ug/kg 1.2 J 1.2 J 1.1 J 1.2 J 1.3 J 5.0 U 5.0 U 5.0 U 5.0 U BENZO(K)FLUORANTHENE ug/kg 1.5 J 1.3 J 1.2 J 1.5 J 1.3 J 5.0 U 5.0 U 5.0 U 5.0 U CHRYSENE ug/kg 2.1 J 2.0 J 1.6 J 3.6 J 2.2 J 5.0 U 5.0 U 5.0 U 5.0 U DIBENZ(A,H)ANTHRACENE ug/kg 5.1 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U 5.0 U FLUORANTHENE ug/Kg 3.1 J 2.9 J 2.6 J 3.1 J 3.2 J 0.68 J 0.84 J 0.60 J 0.53 J FLUORENE ug/Kg 0.65 J 0.45 J 0.61 J 0.61 J 0.51 J 0.40 J 0.48 J 0.38 J 0.53 J INDENO(1,2,3-CD)PYRENE ug/kg 1.2 J 0.99 J 0.92 J 1.1 J 1.1 J 5.0 U 5.0 U 5.0 U 5.0 U NAPHTHALENE ug/Kg 1.8 J 1.3 J 1.5 J 1.7 J 1.8 J 0.67 J 0.89 J 0.40 J 1.1 J PHENANTHRENE ug/Kg 2.1 J 1.8 J 1.8 J 2.8 J 2.1 J 1.2 J 1.5 J 0.95 J 1.2 J PYRENE ug/Kg 2.8 J 2.8 J 2.4 J 2.7 J 3.0 J 0.56 J 5.0 U 0.40 J 5.0 U 

Table 4-17 Tissue Chemistry Results - Nereis virens (Wet Weight)

Unexposed Grand Bay Reference

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Table 4-17 Tissue Chemistry Results - Nereis virens (Wet Weight)

Sample ID

Replicate 123451234

Chemical Name UnitTOTAL LIPIDS PERCENT 0.95 0.84 1.1 0.76 0.91 0.96 1.1 0.97 0.69 TOTAL SOLIDS PERCENT 13.6 12.5 14.2 13.5 13.9 15.5 13.8 13.5 12.2 ANTIMONY mg/kg 0.002 J 0.002 J 0.002 J 0.002 J 0.002 J 0.002 J 0.002 J 0.002 J 0.002 J ARSENIC mg/kg 2.29 2.04 2.09 2.4 2.46 2.08 1.93 1.99 2.05 BERYLLIUM mg/kg 0.0026 J 0.003 0.0033 0.001 J 0.0014 J 0.0019 J 0.0021 J 0.0052 0.0016 J CADMIUM mg/kg 0.0421 0.0433 0.0484 0.0465 0.0427 0.0563 0.0493 0.0441 0.0478 CHROMIUM (TOTAL) mg/kg 0.13 0.14 0.17 0.09 0.1 0.14 0.25 0.19 0.07 COPPER mg/kg 1.33 1.15 1.03 1.28 1.11 1.08 0.943 1.5 1.19 LEAD mg/kg 0.101 0.11 0.119 0.085 0.099 0.114 0.115 0.125 0.11 MERCURY mg/kg 0.02 0.017 0.019 0.02 0.017 0.02 0.017 0.018 0.018 NICKEL mg/kg 0.311 0.296 0.356 0.373 0.268 0.856 0.494 0.477 0.47 SELENIUM mg/kg 0.12 J 0.15 0.17 0.15 0.17 0.15 J 0.19 0.12 J 0.11 J SILVER mg/kg 0.0195 0.0116 0.0145 0.0113 0.0141 0.0096 0.0081 0.0093 0.0099 THALLIUM mg/kg 0.0007 J 0.0009 J 0.001 J 0.0003 J 0.0005 J 0.0007 J 0.0007 J 0.0014 J 0.0008 J 

ZINC mg/kg 30.5 *N 15 *N 42.6 *N 8.72 *N 43.4 *N 10.6 *N 18.3 *N 10.1 *N 47.6 *N 1-METHYLNAPHTHALENE ug/Kg NA NA NA NA NA NA NA NA NA 2-METHYLNAPHTHALENE ug/Kg NA NA NA NA NA NA NA NA NA ACENAPHTHENE ug/kg NA NA NA NA NA NA NA NA NA ACENAPHTHYLENE ug/kg NA NA NA NA NA NA NA NA NA ANTHRACENE ug/kg NA NA NA NA NA NA NA NA NA BENZO(A)ANTHRACENE ug/kg NA NA NA NA NA NA NA NA NA BENZO(A)PYRENE ug/Kg NA NA NA NA NA NA NA NA NA BENZO(B)FLUORANTHENE ug/kg NA NA NA NA NA NA NA NA NA BENZO(G,H,I)PERYLENE ug/kg NA NA NA NA NA NA NA NA NA BENZO(K)FLUORANTHENE ug/kg NA NA NA NA NA NA NA NA NA CHRYSENE ug/kg NA NA NA NA NA NA NA NA NA DIBENZ(A,H)ANTHRACENE ug/kg NA NA NA NA NA NA NA NA NA FLUORANTHENE ug/Kg NA NA NA NA NA NA NA NA NA FLUORENE ug/Kg NA NA NA NA NA NA NA NA NA INDENO(1,2,3-CD)PYRENE ug/kg NA NA NA NA NA NA NA NA NA NAPHTHALENE ug/Kg NA NA NA NA NA NA NA NA NA PHENANTHRENE ug/Kg NA NA NA NA NA NA NA NA NA PYRENE ug/Kg NA NA NA NA NA NA NA NA NA Data Qualifiers:U: Undetected; parameter was not detected above the laboratory RL.*: The duplicate analysis not within control limits. J: The result is an estimated concentration that is less than the RL but greater than or equal to the MDL.N: MS/MSD exceed acceptance criteria.NA: Not analyzed per agency recommendation.

Station SB7L Station SB10L 

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Table 4-18 Food and Drug Administration action levels for edible fish and shellfish1

Substance Action Level2

Metals 

 Methyl Mercury 1.0 ppm 

Pesticides 

 Chlordane 0.3 ppm 

 Chlordecone (Kepone) 0.3 ppm 

 DDT + DDE 5.0 ppm 

 Dieldrin + Aldrin 0.3 ppm 

 Heptachlor + Heptachlor Epoxide 0.3 ppm 

 Mirex 0.1 ppm 

Industrial Chemicals 

 PCBs (2.0 ppm)3

1 References: CPG 540.600 (Hg); CPG 575.100 (pesticides). 

2 Action levels are reported in wet weight. 

3 Equal to the previous action level until a tolerance level has been 

established 

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Table 4-19 Mercury tissue upper confidence limit test results (wet weight) 

 Units UCL Mean 

Nereis virens 

SB10L mg/kg 0.0204 0.0188 

SB7L mg/kg 0.0200 0.0186 

SC123 mg/kg 0.0203 0.0168 

Reference mg/kg 0.0290 0.0276 

Unexposed mg/kg 

Macoma nasuta 

SB10L mg/kg 0.0041 0.0036 

SB7L mg/kg 0.0042 0.0038 

SC123 mg/kg 0.0040 0.0032 

Reference mg/kg 0.0053 0.0044 

Unexposed mg/kg 0.0037 0.0030 

FDA Action Level mg/kg 1.0000 

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Table 4-20 Tissue exposure comparisons for detected analytes - Macoma nasuta (wet weight) 

(page 1 of 2) 

 Data Normally Distributed1 t-Test2 Comparison to Unexposed 

Site 

Raw 

(alpha=0.01) 

Ln 

(alpha=0.01) 

p-value 

(alpha=0.05) 

Significant 

Difference 

p-value 

(alpha=0.05) 

Signif. > 

Unexposed3

SB7L 

 Antimony yes - 0.0234 yes Less than unexposed tissue 

 Arsenic Less than Reference4 - - 

 Beryllium Less than Reference4 - - 

 Cadmium yes - 0.4761 no - - 

 Chromium Less than Reference4 - - 

 Copper Less than Reference4 - - 

 Lead Less than Reference4 - - 

 Mercury Less than Reference4 - - 

 Nickel Less than Reference4 - - 

 Selenium Less than Reference4 - - 

 Silver Less than Reference4 - - 

 Thallium Less than Reference4 - - 

 Zinc Less than Reference4 - - 

SB10L 

 Antimony yes - 0.0072 yes Less than unexposed tissue 

 Arsenic Less than Reference4 - - 

 Beryllium Less than Reference4 - - 

 Cadmium yes - 0.0757 no - - 

 Chromium Less than Reference4 - - 

 Copper Less than Reference4 - - 

 Lead Less than Reference4 - - 

 Mercury Less than Reference4 - - 

 Nickel yes - 0.4924 no - - 

 Selenium Less than Reference4 - - 

 Silver Less than Reference4 - - 

 Thallium Less than Reference4 - - 

 Zinc Less than Reference4 - - 

SC123 

 Antimony yes - 0.1865 no - - 

 Arsenic Less than Reference4 - - 

 Beryllium Less than Reference4 - - 

 Cadmium yes - 0.4099 no - - 

 Chromium Less than Reference4 - - 

 Copper Less than Reference4 - - 

 Lead Less than Reference4 - - 

 Mercury Less than Reference4 - - 

 Nickel Less than Reference4 - - 

 Selenium Less than Reference4 - - 

 Silver yes - 0.3216 no - - 

 Thallium Less than Reference4 - - 

 Zinc Less than Reference4 - - 

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Table 4-20 Tissue exposure comparisons for detected analytes - Macoma nasuta (wet weight) 

(page 2 of 2) 

 Data Normally Distributed1 t-Test2 Comparison to Unexposed 

Site 

Raw 

(alpha=0.01) 

Ln 

(alpha=0.01) 

p-value 

(alpha=0.05) 

Significant 

Difference 

p-value 

(alpha=0.05) 

Signif. > 

Unexposed3

SB7U 

 1-Methylnaphthalene Less than Reference4 - - 

 2-Methylnaphthalene Less than Reference4 - - 

 Acenaphthene Less than Reference4 - - 

 Anthracene yes - 0.0118 yes 0.0127 yes 

 Benzo(a)anthracene5 no no 0.1172 no - - 

 Benzo(a)pyrene yes - 0.4465 no - - 

 Benzo(b)fluoranthene Less than Reference4 - - 

 Benzo(k)fluoranthene Less than Reference4 - - 

 Chrysene yes - 0.0018 yes 0.002 yes 

 Fluoranthene yes - 0.0014 yes 0.0015 yes 

 Fluorene yes - 0.0088 yes 0.0036 yes 

 Naphthalene Less than Reference4 - - 

 Phenanthrene yes - 0.0019 yes 0.001 yes 

 Pyrene yes - 0.0008 yes 0.0008 yes 

1

 "Yes" value indicates that both station and reference datasets were normally distributed (t-test performed on either raw 

or log-transformed data). 

2

 A two sample t-test for unequal variance was used to assess differences unless otherwise indicated. 

3

 Samples were compared to the unexposed tissue results if site samples were significantly different from reference. 

4

 Reference mean concentration was greater than site mean concentration. 

5

 Neither raw data nor log-transformed data were normally distributed and the Wilcoxan Rank Sum non-parametric test 

was performed. 

6

 Less than 80 percent of the data were detected; Wilcoxan Rank Sum non-parametric test was conducted. 

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Table 4-21 Tissue exposure comparisons for detected analytes - Nereis virens (wet weight) 

(page 1 of 2) 

 Data Normally Distributed1 t-Test2 Comparison to Unexposed 

Site 

Raw 

(alpha=0.01) 

Ln 

(alpha=0.01) 

p-value 

(alpha=0.05) 

Significant 

Difference 

p-value 

(alpha=0.05) 

Signif. > 

Unexposed3

SB7L 

 Antimony Less than Reference5 - - 

 Arsenic yes - 0.0038 yes Less than unexposed tissue 

 Beryllium yes - 0.0987 no - - 

 Cadmium yes - 0.0028 yes Less than unexposed tissue 

 Chromium Less than Reference5 - - 

 Copper yes - 0.0519 no - - 

 Lead yes - 0.262 no - - 

 Mercury Less than Reference5 - - 

 Nickel yes - 0.0072 yes Less than unexposed tissue 

 Selenium yes - 0.2765 no - - 

 Silver Less than Reference5 - - 

 Thallium Less than Reference5 - - 

 Zinc Less than Reference5 - - 

SB10L 

 Antimony Less than Reference5 - - 

 Arsenic yes - 0.0257 yes Less than unexposed tissue 

 Beryllium yes - 0.052 no - - 

 Cadmium yes - 0.0034 yes Less than unexposed tissue 

 Chromium yes - 0.3233 no - - 

 Copper yes - 0.1296 no - - 

 Lead yes - 0.0417 yes Less than unexposed tissue 

 Mercury Less than Reference5 - - 

 Nickel yes - 0.0025 yes Less than unexposed tissue 

 Selenium Less than Reference5 - - 

 Silver Less than Reference5 - - 

 Thallium6 no no 0.1719 no - - 

 Zinc Less than Reference5 - - 

SC123 

 Antimony Less than Reference5 - - 

 Arsenic yes - 0.0303 yes Less than unexposed tissue 

 Beryllium yes - 0.4758 no - - 

 Cadmium Less than Reference5 - - 

 Chromium Less than Reference5 - - 

 Copper Less than Reference5 - - 

 Lead yes - 0.4641 no - - 

 Mercury Less than Reference5 - - 

 Nickel yes - 0.2885 no - - 

 Selenium Less than Reference5 - - 

 Silver Less than Reference5 - - 

 Thallium Less than Reference5 - - 

 Zinc Less than Reference5 - - 

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Table 4-21 Tissue exposure comparisons for detected analytes - Nereis virens (wet weight) 

(page 2 of 2) 

 Data Normally Distributed1 t-Test2 Comparison to Unexposed 

Site 

Raw 

(alpha=0.01) 

Ln 

(alpha=0.01) 

p-value 

(alpha=0.05) 

Significant 

Difference 

p-value 

(alpha=0.05) 

Signif. > 

Unexposed3

SB7U 

 1-Methylnaphthalene yes - 0.1927 no - - 

 2-Methylnaphthalene yes - 0.0339 yes Less than unexposed tissue 

 Acenaphthene < 50% detected data. 4

 Acenaphthylene < 50% detected data. 4

 Anthracene < 50% detected data. 4

 Benzo(a)pyrene no yes 0.498 no - - 

 Fluoranthene yes - 0.0021 yes Less than unexposed tissue 

 Fluorene6 no no 0.6004 no - - 

 Naphthalene yes - 0.0509 no - - 

 Phenanthrene yes - 0.0343 yes Less than unexposed tissue 

 Pyrene7 - - 0.5993 no - - 

1

 "Yes" value indicates that both station and reference datasets were normally distributed (t-test performed on either raw 

or log-transformed data). 

2

 A two sample t-test for unequal variance was used to assess differences unless otherwise indicated. 

3

 Samples were compared to the unexposed tissue results if site samples were significantly different from reference. 

4

 < 50% detected data, statistics were not calculated. 

5

 Reference mean concentration was greater than site mean concentration. 

6

 Neither raw data nor log-transformed data were normally distributed and the Wilcoxan Rank Sum non-parametric test 

was performed. 

7

 Less than 80 percent of the data were detected; Wilcoxan Rank Sum non-parametric test was conducted. 

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Table 4-22 Bioaccumulation significance testing - tissue concentrations statistically greater at site vs 

reference1

 Macoma nasuta Nereis verens 

Parameter SB7L SB10L SC123 SB7U SB7L SB10L SC123 SB7U 

 Antimony Y Y N - R R R - 

 Arsenic R R R - Y Y Y - 

 Beryllium R R R - N N N - 

 Cadmium N N N - Y Y R - 

 Chromium R R R - R N R - 

 Copper R R R - N N R - 

 Lead R R R - N Y N - 

 Mercury R R R - R R R - 

 Nickel R N R - Y Y N - 

 Selenium R R R - N R R - 

 Silver R R N - R R R - 

 Thallium R R R - R N2 R - 

 Zinc R R R - R R R - 

 1-Methylnaphthalene - - - R - - - N 

 2-Methylnaphthalene - - - R - - - Y 

 Acenaphthene - - - R - - - ND5

 Acenaphthylene - - - ND4 - - - ND5

 Anthracene - - - Y - - - ND5

 Benzo(a)anthracene - - - N2 - - - ND4

 Benzo(a)pyrene - - - N - - - N 

 Benzo(b)fluoranthene - - - R - - - ND4

 Benzo(g,h,i)perylene - - - ND4 ND4

 Benzo(k)fluoranthene - - - R - - - ND4

 Chrysene - - - Y - - - ND4

 Dibenz(a,h)anthracene - - - ND4 - - - ND4

 Fluoranthene - - - Y - - - Y 

 Fluorene - - - Y - - - N2

 Indeno(1,2,3-cd)pyrene - - - ND4 - - - ND4

 Naphthalene - - - R - - - N 

 Phenanthrene - - - Y - - - Y 

 Pyrene - - - Y - - - N3

1

Tests were conducted using two sample t-tests on normally distributed data unless otherwise noted. 

Significance codes as follows: 

 Y=parameter concentrations were significantly greater in site exposed tissues than in reference exposed tissues

 N=parameter concentrations were not significantly greater in site tissues versus reference 

 R=reference mean concentration was greater than site mean concentration 

2

 Neither raw data nor log-transformed data were normally distributed and the Wilcoxan Rank Sum non-parametric 

test was performed. 

3

 Less than 80 percent of the data were detected; Wilcoxan Rank Sum non-parametric test was conducted. 

4

 Parameter was not detected in any study or reference site replicate 

5

 Less than 50% of the data were detected values 

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Table 4-23 Mean tissue concentrations associated with results that are statistically greater than 

reference (wet weight) 

Parameter Units Unexposed Ref SB7L SB10L SC123 SB7U CBR Conc1

Macoma nasuta exposures

Antimony mg/Kg 0.018 0.013 0.015 0.017 - - NA 

Anthracene ug/Kg 0.18 J 0.15 J - - - 1.30 J NA 

Chrysene ug/Kg 0.48 J 0.45 J - - - 1.19 J 9302

Fluoranthene ug/Kg 2.08 J 2.08 J - - - 10.2 9,040 

Fluorene ug/Kg 0.41 J 0.54 J - - - 0.93 J NA 

Phenanthrene ug/Kg 1.3 J 2.94 J - - - 8.44 780 

Pyrene ug/Kg 1.03 J 1.06 J - - - 5.02 K 0.8-330,0002

Nereis verens exposures

Arsenic mg/Kg 2.52 1.79 2.26 2.07 2.07 - 1.15-6.39 

Cadmium mg/Kg 0.051 0.039 0.045 0.051 - - 0.004-290 

Lead mg/Kg 0.440 0.096 - 0.115 - - 0.58-70 

Nickel mg/Kg 0.70 0.21 0.32 0.59 - - 79 

2-Methylnaphthalene ug/Kg 0.81 J 0.52 J - - - 0.71 J NA 

Fluoranthene ug/Kg 2.98 J 0.63 J - - - 2.04 J 9,040 

Phenanthrene ug/Kg 2.12 J 1.14 J - - - 1.82 J 780 

1

Critical body residue concentrations - refer to Table 4-24 

2

CBR data represent freshwater organism NOEC for selected parameters; marine organism data are not 

available 

NA: CBR data are not available for selected parameters 

J: All replicates were measured below the laboratory reporting limit. Station means were calculated using 

estimated values 

K: Pyrene was measured below the laboratory reporting limit in 3 of 5 station SB7U replicates 

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Table 4-24 Critical body residue concentrations (mg/kg wet)1

Measured Effect 

Parameter Mortality Growth 

Physiological/ 

Developmental Reproduction 

Antimony -- -- -- -- 

Arsenic 3.6 [Me] 1.15 - 6.39 [Pp] -- -- 

Cadmium 0.9 [Pp] - 62 [Na] 1.12 [Na] - 150 [Nv] 0.004 [Cg] -290 [Nv] 3.6 [Na] - 90 [Pf] 

Lead 0.58 [Pl] - 70 [Pi] 2.28 [Cv] -- 2.6 [Cv] 

Nickel 79 [Ce] 575 [Ce] 167 [Ce] -- 

Anthracene -- -- -- -- 

Chrysene 0.93 [Dp]2 -- -- -- 

Fluoranthene 68.7 [Lp] - 1,280 [Mr] -- -- 40.45 [Sk] - 121.4 [C sp-a] 

Fluorene -- -- -- -- 

2-Methylnaphthalene -- -- -- -- 

Phenanthrene 0.78 [Na] -- -- -- 

Pyrene 0.0008 - 330 [Lv]2 -- 890 - 1,480 [D sp]2 -- 

Notes: 1Values are no effect concentrations (NOECs). 2Freshwater organism. Marine organism uptake data not found. 

-- = No value not found No marine species CBR data found for: anthracene, antimony, chrysene, fluorene, 2-methylnapthalene, pyrene and thallium. Species codes (Marine/Estuarine organisms): 

[Bc] Balanus crenatus Barnacle [Me] Mytilus edilus B

[C sp] Capitella sp Polychaete [Mr] Monopylephorus rubroniveus O

[C sp-a] Coullana sp Copepod [Na] Neanthes arenaceodentata N

[Ce] Cerastoderma edule Clam [Nv] Nereis virens P[Cg] Crassostrea gigas Pacific oyster [Pf] Platichthys flesus E

[Cv] Crassostrea virginica Eastern oyster [Pi] Panaeus indicus C[Hv] Hydrobia ulvae Prosobranch mud snail [Pl] Patacentrotus lividus S

[Lp] Leptocheirus plumulosus Amphipod [Pp] Palaemonetes pugio S

[Mb] Macoma balthica Baltic macoma [Sk] Schizopera knabeni c

Species codes (Freshwater organisms): 

[D sp] Diporeia spp. Amphipod [Lv] Lumbriculus variegatus O

[Dp] Dreissena polymorpha Mussel - Zebra 

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Figure 4-1 Casotte Landing Phase 2 Sediment Grain Size 

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Figure 4-2 Example Metal to Aluminum Regression Findings 

y = 4705.5x + 10828

R2

 = 0.9363

0

10000

20000

30000

40000

50000

60000

70000

80000

0 2 4 6 8 10 12

Copper (mg/kg)

Aluminum (%)

14

y = 4276x + 1227.8

R2

 = 0.9878

0

10000

20000

30000

40000

50000

60000

70000

80000

0 5 10 15 20

Lead (mg/kg)

Aluminum (%)

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Figure 4-3 Chemical Ratios-to-Reference: Metals 

0.00

1.00

2.00

3.00

4.00

5.00

6.00

7.00

8.00

9.00

10.00

Station

Reference Ratio

ANTIMONY

ARSENIC

BERYLLIUM

CADMIUM

CHROMIUM

COPPER

LEAD

MERCURY

NICKEL

SELENIUM

SILVER

THALLIUM

ZINC

C1U C2U C2UDUP SB4U SB7U SB9U SB10U SB11U SB12U 

Upper Layer

0.00

1.00

2.00

3.00

4.00

5.00

6.00

7.00

8.00

9.00

10.00

Station

Reference Ratio

ANTIMONY

ARSENIC

BERYLLIUM

CADMIUM

CHROMIUM

COPPER

LEAD

MERCURY

NICKEL

SELENIUM

SILVER

THALLIUM

ZINC

C3L C4L C4LDUP SB7L SB10L SB12L

Lower Layer

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Figure 4-4 Chemical Ratios-to-Reference: Non-Metals 

0

1

2

3

4

5

6

7

Station

Station/Reference

SULFIDE

AMMONIA

NITRATE + NITRITE

NITROGEN, KJELDAHL,

TOTAL

PHOSPHOROUS

C1U C2U C2UDUP SB4U SB7U SB9U SB10U SB11U SB12U 

Upper Layer

0

1

2

3

4

5

6

7

Station

Station/Reference

SULFIDE

AMMONIA

NITRATE + NITRITE

NITROGEN, KJELDAHL,

TOTAL

PHOSPHOROUS

C3L C4L C4LDUP SB7L SB10L SB12L 

Lower Layer

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Figure 4-5 Chemical Ratios-to-Reference: PAH Compounds 

July 2006 

0

1

2

3

Station

Station/R4

5

6

7

8

eference

Total PAHs

0

1

2

3

4

5

6

7

8

Station

Station/Reference

 C1U C2U C2UDUP SB4U SB7U SB9U SB10U SB11U SB12U 

Upper Layer

Total PAHs

C3L C4L C4LDUP SB7L SB10L SB12L 

Lower Layer

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Non-Internet Public 

 

 

 

 

 

 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Appendix E-1 page 97 

Figure 4-6 NOAA National Status and Trends Sediment 

Monitoring Stations

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Figure 4-7 Comparison of Metals in CLLNG Sediments to National Status and Trends and Grand Bay 

Reference Sediments (Page 1 of 2) 

0

5

10

15

20

25

30

35

Heron Bay - NS&T

North Point - NS&T

Pascagoula River - NS&T

Round Island -

NS&T

Grand Bay Ref

CLLNG Upper

CLLNG Lower

Normalized to Al (*104

)

Arsenic (*10)

Chromium

Zinc

0

1

2

3

4

5

6

7

Heron Bay - NS&T

North Point - NS&T

Pascagoula River - NS&T

Round Island - NS&T

Grand Bay Ref

CLLNG Upper

CLLNG Lower

Normalized to Al (*104

)

Copper

Lead

Nickel

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Figure 4-7 Comparison of Metals in CLLNG Sediments to National Status and Trends and Grand Bay 

Reference Sediments (Page 2 of 2) 

0

5

10

15

20

25

Heron Bay - NS&T

North Point - NS&T

Pascagoula River - NS&T

Round Island - NS&T

Grand Bay Ref

CLLNG Upper

CLLNG Lower

Normalized to Al (*106

)

Cadmium

Selenium

Thallium

0

1

2

3

4

5

6

7

Heron Bay - NS&T

North Point - NS&T

Pascagoula River - NS&T

Round Island - NS&T

Grand Bay Ref

CLLNG Upper

CLLNG Lower

Normalized to Al (*106

)

Antimony

Mercury

Silver

Error bars represent 1 standard deviation and are included when n > 2. 

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Error bars represent 1 standard deviation and are included when n > 2. 

Figure 4-8 Comparison of PAHs, PCBs, and Pesticides in CLLNG Sediments to NS&T and Grand Bay 

Reference Sediments 

0

50

Heron Bay - NS&T

North Point - NS&T

Pascagoula River - NS&T

Round Island - NS&T

Grand Bay R

100

150

200

250

300

ef

CLLNG Upper

CLLNG Lower

ug/kg

Total PAHs

Total PCBs *10

Total DDT *10

Total Pesticides (non-DDT) *100

=447

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Figure 4-9 Example Amphipod Test Chamber 

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5.0 Conclusions and MPRSA Section 103 considerations 

This section provides an evaluation of the proposed CLLNG slip area material to be dredged. Dredgingspecific information is provided in the project Dredged Material Management Plan. 

A tiered approach for the evaluation of the suitability of dredged material for open water placement is 

described in Federal and regional guidance documents (EPA/USACE, 1991; EPA/USACE, 1993). In some 

cases, the full set of testing requirements is not necessary, depending upon what is already known about the 

material makeup and/or characteristics. For this reason, EPA and USACE have developed a framework that 

allows collection of sufficient information to evaluate the material suitability, without the expense of conducting 

the full range of chemical and biological testing. Four tiers are defined: 

Tier I – Assess existing sediment information; 

Tier II – Chemical assessments. Sediment and water column (elutriate) simulations; 

Tier III – Bioassays. Bulk sediment, water column (suspended particulate phase), and bioaccumulation 

bioassays; and 

Tier IV – Site-specific testing. Test organisms unique to the site or, in the case of Casotte Landing 

sediment material, protocol modifications to address site-specific conditions. 

Tier I investigations involve the assessment of existing information and is commonly all that is needed if, for 

example, the material is sand or gravel without a history of spills or detrimental impacts. The project SAP 

summarizes available historical data, although within the limited slip area, little information was available. 

Therefore, the full range of chemical and biological tests under Tiers II, III, and IV were undertaken to support 

Section 103 suitability decision-making. 

Tier II and III investigations, corresponding to chemical and biological testing, respectively, have been defined 

in Section 2. The bulk sediment amphipod test protocol, modified to address the lack of bioavailable carbon 

(food) in site material, may be considered a Tier IV assessment since the information provided in the first three 

tiers was insufficient to support decision-making. 

For simplicity, conclusions related to Section 103 decision-making have been grouped under the three primary 

exposure/ecological pathways (sediment exposure, water column effects, and bioaccumulation) since some 

pathways are addressed in multiple testing tiers. 

5.1 Sediment exposure 

From a chemical standpoint, the sediment tested from within the proposed Casotte Landing slip area is 

generally very clean. Of the wide range of potential contaminants evaluated in this study and outlined in the 

project SAP (ENSR, 2005), many were not detected in the material to be dredged. Of those detected, very 

few were above concentrations observed in surface sediments at the regional (Grand Bay) reference site. 

When compared to ERLs and ERMs, two samples analyzed in Phase 1 exceeded ERL thresholds by a minor 

amount (SB4UU1 for As and Hg, and SB7U1 for acenaphthene) and none of the Phase 2 sample set 

exceeded the ERL benchmark (Tables 4-2 and 4-3). Most organic contaminants were not detected or were 

measured below laboratory reporting limits. 

The sediment bioassay information also indicates that slip sediments are clean. The fact that sedimentary 

carbon is of questionable value to organisms as a food source presented a confounding factor that needed to 

be addressed to better evaluate the sediment quality. High survivorship was observed for the mysid shrimp 

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test organisms when exposed to the sediment for 10 days. The amphipod survival was also within the 

acceptance limits relative to reference survival as long as TetraMinTM supplements were provided on day 0 

and 5 to augment the nutrient-poor sediment matrix. 

5.2 Water column effects 

The SPP bioassays and the chemical elutriates measured in the aqueous samples did not indicate any water 

quality concerns beyond the allowable mixing zone or the allowed 4-hour mixing period. Limiting Permissible 

Concentrations (LPCs) based on the worst case SPP result (an EC50 of 50.8%; Table 4-11) have been 

modeled using the regulatory model STFATE and the results are summarized in Figure 5-1. The simulation 

was performed using different barge loading scenarios, with the worst case conditions for two potential vessel 

sizes incorporated in the evaluation. Vessels in the 3,000 cubic yard (cy) size range are commonly used for 

transporting dredged material, but larger 5,000 cy barges are also available and may be used for the project; 

therefore, the simulations incorporated both of these options. 

STFATE simulations predict that the LPC is met everywhere within the ODMDS after 2.2 to 2.5 hours from the 

initial discharge. Predictions related to the plume centroid location estimate travel distances of 600 to 1100 

feet from the barge discharge point for the 3,000 and 5,000 cy vessels, respectively. Model inputs for these 

simulations are summarized in Table 2-3, complete input and output files are provided in Appendix F. 

Aqueous chemical measurements related to the elutriate samples were also very low relative to water quality 

standards with few exceptions. Three inorganic parameters (Hg, Ni, phosphorous) exceeded the standard in 

undiluted elutriate samples, but because LPCs identified in the SPP tests required greater dilution to meet 

acceptance criteria, these chemical data were not evaluated further and only the worst case SPP findings 

were simulated using STFATE. 

Overall, the fact that SPP bioassay test organisms were mostly unaffected when exposed to suspended 

sediment mixtures (which are typically the most sensitive biological indicator) further underscores the overall 

quality of the material planned for dredging at Casotte Landing. 

5.3 Bioaccumulation findings 

Very few sites required evaluating potential bioaccumulative concerns based on the sediment chemistry 

results and the fact that most compounds and metals were either not detected or measured at concentrations 

less than Grand Bay reference values. Furthermore, only metals and PAH compounds required analysis in 

tissues exposed to these few stations. 

Metals were analyzed in the test organism tissues exposed to 3 of the 13 sites (SB7L, SB10L, and SC123) 

and PAH analysis was required of tissues exposed to just one of the stations (SB7U) relative to referenceexposed tissues. 

In the final analysis, only five metals and seven PAH compounds were measured in site-exposed tissue at 

statistically greater concentrations than reference-exposed tissue. The metal concentrations were, however, 

less than pre-exposure clam and worm tissue concentrations and in the range of available NOECs. The PAH 

compound concentrations in worm tissues were also lower than those of pre-exposed tissues and also lower 

than available NOEC data for marine organisms. In Macoma clam tissues, the six PAH compounds measured 

as statistically greater in site-exposed versus reference-exposed tissues were also at concentrations higher 

than pre-exposed clam tissues but were nonetheless measured at very low concentrations (many were still 

below laboratory reporting limits) and well below or within the range of tissue residue NOECs (Tables 4-23 and 

4-24). 

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5.4 Conclusions 

Several lines of evidence evaluated in this investigation provide a basis for agency Section 103 decisionmaking: 

• Bulk sediment evaluations performed in this study provide a large weight-of-evidence that the material 

to be dredged is clean from a chemical perspective. Further, test organisms appear to be healthy 

after exposure tests, although given the unique low biogenic carbon sediment content, the material 

may not provide a sufficient food source to deposit feeders until biogenic particles, raining down from 

the overlying water column, accumulate on the sediment surface for some weeks or months. 

• Water column (SPP) bioassay tests, often the most sensitive indicators of biological effects, measured 

very good survival and development results by the time SPP mixtures were diluted in half. STFATE 

simulations predict LPCs would be reached well within the 4-hour threshold and that related water 

column plumes would not travel very far. 

• Lastly, because of the relatively clean nature of the site overall, only a few stations required further 

evaluation of potential bioaccumulative concerns. Of the many parameters measured, only six were 

at concentrations statistically greater than those of reference-exposed and pre-exposed tissue levels. 

The few compounds measured at concentrations above pre-exposed tissue concentrations were 

nonetheless well within available NOEC observations for aquatic organisms. 

In conclusion, the many evaluations conducted in this study provide a large weight-of-evidence that exposure 

to the Casotte Landing sediment dredged from the slip area will have little or no biological effect on the marine 

environment at the ODMDS beyond initial burial of the benthos. These findings provide a firm basis for agency 

decision-making. 

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FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED CASOTTE LANDING LNG TERMINAL 

AND PIPELINE PROJECT 

Docket No. CP05-420-000 

Appendix E-1 page 105 

Figure 5-1 STFATE Model Results for 3,000 and 5,000 cy Barge 

No Overflow Scenario

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
6.0 Project QA/QC findings 

This section provides quality control information and documents the overall quality of the data upon which the 

project conclusions are drawn. Selected data are summarized in the subsections that follow. 

6.1 Biological testing QA/QC 

This section provides QA/QC information related to the biological testing effort including organism sources, 

organism age, and reference toxicant tests. All toxicity testing was conducted by ESI of Hampton, New 

Hampshire, with the exception of the additional L. plumulosus testing conducted by Weston Solutions located 

in Port Gamble, Washington. 

The ESI control seawater, used as overlying water in whole sediment tests and as the laboratory control 

treatment for the SPP assays, was obtained from the Hampton Estuary. This water source has been used for 

the culture and maintenance of test organisms at ESI since 1978. This seawater is classified as SA-1, is 

obtained from a point on the bottom of the estuary approximately 1 mile from the open ocean, and is filtered 

prior to use. The control seawater for Weston Solutions testing was natural seawater from North Hood Canal 

in Port Gamble, Washington that was filtered through a 3-μm filter prior to use in the assays. 

6.1.1 Whole sediment toxicity bioassays 

ESI used A. bahia organisms cultured and maintained by Aquatic Research Organisms (ARO), Hampton, New 

Hampshire. Prior to use, test organisms were held for at least 2 hours under temperature, salinity, and 

photoperiod conditions similar to those used in the assay. A. bahia used in the assay were 4 days old at the 

start of the test on January 20, 2006. The control sediment used in the A. bahia assays was an artificial 

sediment consisting primarily of silica sand prepared at ESI. 

Both ESI and Weston Solutions obtained laboratory cultured L. plumulosus organisms from ARO. Organisms 

were maintained by ESI for 24 hours prior to use in the assay (organisms are delivered directly to ESI by 

ARO). Weston Solutions maintained organisms in-house for 4 to 5 days after shipment and prior to test 

initiation. The amphipods selected for testing were juveniles, with age based on size. Control sediment used 

in the L. plumulosus assays was provided by ARO. The testing conducted at ESI started on January 20, 2006 

and the three batches of testing conducted by Weston started on April 4, April 11, and May 16, 2006. 

Specifics of the initial L. plumulosus assay conducted by ESI are not discussed below since the assay was 

repeated. The following sections address the reference toxicant assays and protocol deviations associated 

with the L. plumulosus assay conducted by Weston Solutions. 

6.1.1.1 Reference toxicants 

As part of the laboratory quality control program, standard reference toxicant assays are conducted on a 

regular basis for each test species. ESI started an acute 96-hour copper reference toxicant assay for A. bahia

on January 31, 2006. Results were outside two standard deviation of the historic mean. However, based on 

normal statistical variation, it is expected that 1 in 20 reference toxicant assays will fall outside the acceptable 

range. This reference toxicant assay was not started with the batch of organisms used in the 10-day test but 

was conducted with organisms obtained from the same supplier. The laboratory controls for the 10-day assay 

met the acceptability criteria indicating that the test organisms were healthy. 

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Weston conducted an acute 96-hour copper reference toxicant assay with each of the three batches of tests. 

Results for all three reference toxicant assays control chart limits of two standard deviations of the historic 

mean. The laboratory controls for the 10-day assays associated with these reference toxicant assays met the 

acceptability criteria indicating that the test organisms were healthy. 

6.1.1.2 Whole sediment protocol deviations 

Water quality data were not collected in all replicates of the A. bahia assay on Day 10 as specified due to a 

technician error. Water temperatures of 18°C were recorded in selected samples on Days 4, 6, and 7 in the 

A. bahia assay. This is below the 20±1°C specified in the QAPP. In six of the replicates additional A. bahia

above the 20 added at test initiation were recovered. These additional test organisms were recovered from 

the following samples: C2U, SB10U, C3L, SB7L, and SC123 (two replicates). In three cases one additional 

organism was recovered, in one case two additional organisms were recovered, and in two cases five 

additional organisms were recovered. The additional organisms were the result of technician counting error 

during addition of the organisms to test chambers. For the purpose of statistical analysis, these replicates were 

considered to have had 100 % survival. Due to the random nature of this issue, this deviation did not greatly 

impact the results of any one sample set. Although the SC123 sample had two impacted replicates, the 

survival in the remaining replicates was high (95% to 100%) and consistent with the 100% assumption for the 

two replicates with additional organisms. 

Minor temperature, salinity, and dissolved oxygen deviations were observed during the three batches of 

L. plumulosus testing conducted by Weston. The lowest temperature recorded was 1.6°C below range 

specified in the QAPP. Salinity was slightly above the target range towards the end of some assays, likely due 

to evaporation. Dissolved oxygen below the range specified in the QAPP was recorded in selected replicates 

but returned to within the specified range by the following day after the aeration level was increased. 

These deviations are considered to have had no impact on the outcome of the assay. 

6.1.2 Suspended particulate phase bioassays 

A. bahia, 3-5 days old, were obtained from cultures maintained by ARO. M. beryllina, 10 days old, were also 

obtained from ARO. Prior to use, test organisms were held for a minimum of 2 hours under temperature, 

salinity, and photoperiod conditions similar to those used in the assay. Organisms were transferred to test 

vessels using a large bore pipet to minimize the amount of water added to test solutions. Twenty 

representative fish, measured at the start of the assay, were used to confirm that the recommended organism 

loading rate (<0.40 g/L) suggested for acute assays was not exceeded. 

Adult A. punctulata were from cultures maintained by ESI. Original stock was obtained from a commercial 

supply. Adult sea urchins are maintained in the laboratory for approximately two weeks prior to use. Adult sea 

urchins were maintained in culture at a temperature of approximately 20±3°C during culture. 

6.1.3 Reference toxicants 

Acute 96-hour copper reference toxicant assays for A. bahia and M. beryllina were started on January 31, 

2006. As discussed above, results from the A. bahia assay were outside two standard deviations of the 

historic mean. However, survival in all A. bahia laboratory controls exceeded the minimum acceptability 

criteria in all assays indicating that the test organisms were healthy. The A. punctulata reference toxicant 

assay was started on February 2, 2006. Results of the M. beryllina and A. punctulata assays were within two 

standard deviations of the historic mean for each species. Laboratory controls for these species also exceeded 

the minimum acceptability criteria for each batch of testing indicating that the test organisms were healthy. 

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6.1.4 Protocol Deviations 

The A. punctulata assay started on February 2, 2006, did not meet acceptability criteria and sufficient fertilized 

embryos could not be generated for the assay planned to start on February 8, 2006. The re-test of these two 

assays was started on February 11, 2006. This was 2 and 3 days outside the 14 day hold time for the Bayou 

Casotte water and the ODMDS reference water, respectively. CE SAM and EPA were notified of this 

condition. 

Review of salinity data collected during the daily water quality monitoring for the mysid and minnow assays 

showed variations greater than the limit specified by the protocol. The increase in salinity was usually noted 

as having occurred during the last 24 hours of the assay, and was determined to be the result of evaporation. 

In the majority of the cases, the variation was not more than 3‰. Over the course of all of the assays, the 

salinity ranged from a minimum of 26‰ to a maximum of 35‰. In all cases, the salinity levels were within the 

tolerance limits for the species. 

Temperatures outside the 20±1°C specified in the QAPP were also recorded. In general, the temperatures 

ranged from 18oC to 22 oC. However, temperatures of 16oC and 17oC were recorded at test termination in the 

A. punctulata assay for the laboratory control, ODMDS reference water, and samples SB7U2 and C3L. 

Review of the data indicated that temperatures for other samples in this batch of tests were within the 

acceptable range specified by the protocol, as were the incubator temperatures. The A. punctulata laboratory 

control survival for this batch exceeded the test acceptability criteria, and was consistent with the laboratory 

controls in the other two batches, indicating that the low temperatures did not have a significant impact. Water 

quality measurements were not recorded at the end of the A. punctulata tests started on February 11, 2006. 

The A. punctulata assays were generally extended beyond the 72 hours indicated in the QAPP. However, test 

termination is indicated when >70% of the laboratory control organism reach the pluteus stage and >70% have 

developed normally. The fact that this generally occurred beyond 72 hours does not preclude a valid assay. 

These deviations are considered to have had no impact on the outcome of the assay. 

6.1.5 28-day sediment bioassay/bioaccumulation tests 

Macoma nasuta, 15-40 mm in total length, were obtained from ARO. At ESI, the clams were placed in flowing 

seawater and monitored for at least 24 hours prior to use. Damaged bivalves and those that would not close 

when prodded were discarded. The Macoma test commenced on February 2, 2006. A total of 30 organisms 

were added to each replicate in order to obtain sufficient tissue at test termination. 

Adult Nereis virens were obtained from the Maine Bait Company, Newcastle, Maine. Worms were collected in 

the field and shipped to ESI via overnight delivery. Worms were placed in control sediment and flowing 

seawater and monitored for at least 24 hours prior to use. Damaged and inactive worms were not used in the 

assay that commenced on February 15, 2006. A total of 20 organisms were added to each replicate in order to 

obtain sufficient tissue at test termination. 

6.1.5.1 Protocol deviations 

During the assays, salinity values were reported outside of the salinity regime of 28 ±2‰ established for the 

assays. Mean salinity fell within the specified limits but there were individual data points outside the specified 

ranges. Maximum and minimum salinity levels were reported as 32 and 23‰, respectively. These values fell 

within the overall range specified in the Inland Testing Manual. The variations in salinity were within normal 

ranges for the species. As there was no evidence of adverse impacts on survival of organisms in the 

laboratory control treatment the fluctuations in salinity were determined to have had no significant adverse 

effect on the outcome of the assays. 

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In several replicates of the M. nasuta assay, there were more than 30 bivalves recovered from the sediments 

relative to the 30 placed in chambers at the start. The number of bivalves added to replicate “D” of the 

laboratory control was 20 instead of 30. When there was a variance between the final count and start number 

the existence of the variance was confirmed by counting recovered shells. 

These deviations are considered to have had no impact on the outcome of the assay. 

6.2 Chemical analyses QA/QC 

The chemical data collected during the investigation was of sufficient quality and sensitivity to meet the project 

objectives. The majority of the QC results associated with the analytical parameters met the measurement 

objectives presented in Section A.7.2 of the QAPP. Nonconformances with those measurement objectives are 

presented below. A full set of QC sample findings (method blanks, duplicate precision results, laboratory 

control sample results, and matrix spike results) is provided in Appendix C-1, Chemistry Laboratory Data. 

6.2.1 Analytical sensitivity 

The sensitivity of program chemical measurements can sometimes dictate the ultimate usefulness of the final 

data. Results that are insufficiently sensitive to detect changes can limit the final project conclusions. The 

CLLNG project required reporting limits (RLs) were specified in the agency approved QAPP (ENSR, 2005) to 

detect sedimentary contaminant considerations, ambient seawater and elutriate concentrations, and 

bioaccumulative tissue concerns. 

The QAPP prepared by ENSR for the project (ENSR, 2005) summarized the laboratory RLs and project 

required RLs. Method detection limits (MDLs) were used as the lower limit for quantitations. Laboratory MDLs 

represent an annual statistical MDL study and were conducted in accordance with 40 CFR Part 136 

Appendix B. Nondetect chemistry results were reported at laboratory RLs (typically higher than MDLs by a 

factor of 3 to 10) since they provide greater confidence. Concentrations detected between the MDLs and RLs 

were qualified and reported by the laboratory. 

The majority of the RLs for all sample matrices met the QAPP specifications. Some deviations from QAPPspecified limits occurred when dilutions were needed to overcome matrix interferences or when sample mass 

or moisture content varied considerably. The fact that results were reported between the MDL and RL for 

most parameters further minimizes any concern related to these deviations. 

6.2.2 Contamination concerns 

Sample contamination can sometimes affect sample results, particularly when measuring chemical parameters 

at very low concentrations. In this study, potential contamination has been monitored using method blank, 

filter blank, and equipment blank QC samples. In this study, a few analytes were detected in the laboratory 

method blanks for various parameters but only at very low concentrations between MDLs and RLs. A full 

discussion of QC sample results is included in Appendix C-2, Data Validation Findings. 

Filter blanks, consisting of analyte-free water passed through the membranes used to filter elutriate samples 

for dissolved metals (see Section 2.2.4), were collected at a frequency of one per 10 elutriate samples. Only 

Cu was detected in filter blanks at concentrations slightly above the RL. Several other metals were detected 

though at concentrations below the RL. 

Equipment blanks were collected at the frequency stated in the QAPP for soil/sediment and aqueous samples. 

Various analytes were detected in the equipment blanks; however, the majority of these concentrations were 

reported as estimated concentrations below the RLs. Some analytes (mostly metals) were reported at 

concentrations that exceeded the RLs, however, the presence of blank contamination (field or laboratory) 

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would potentially yield false positive results and so these findings do not affect project conclusions protective of 

the environment. 

6.2.3 Data precision 

Analytical precision was measured at the laboratory level using matrix duplicates (inorganic parameters), and 

laboratory control sample (LCS) duplicates or matrix spike duplicates (organic parameters). Field precision 

was measured using field duplicate samples. Laboratory and field precision is discussed below and in 

Appendix C-2, Data Validation Findings. 

6.2.3.1 Field precision 

To evaluate precision, relative percent differences (RPDs) were calculated and compared to the data quality 

objectives stated in the QAPP for solid samples (<50% RPD) and aqueous samples (<30% RPD). The 

majority of the RPDs were <50% for the soil/sediment field duplicate pairs. Exceedances of the sediment 

criterion were generally related to metal and PAH measurements and exceedances of the elutriate criterion 

were generally related to metal measurements. However, in all cases the sample results associated with the 

high RPDs were close to the RLs for those analytes, where small differences can result in large RPD values. 

Related precision in these instances is considered acceptable. 

6.2.3.2 Laboratory analysis precision 

Sediment measurement precision 

Sediment analysis precision was evaluated using matrix duplicates for inorganic parameters and matrix spike 

duplicates or LCS duplicates for organic parameters. RPD objectives for this project ranged from 20 to 50% 

for matrix spike duplicates (depending on the parameter) and 20% for matrix duplicates and LCS duplicates. 

In general, the RPD criteria were met for all parameters. The RPDs for fluoranthene and arsenic exceeded the 

duplicate criteria in one batch of samples analyzed for the Rapid TAT (Phase 1) sediments, but because 

Phase 1 data were primarily used to develop pooling schemes for (full) Phase 2 testing, the project 

conclusions are unaffected by these nonconformance issues. 

The laboratory inadvertently omitted matrix spike duplicate analyses for VOCs for the Rapid TAT (Phase 1) 

sediments. However, acceptable LCS duplicate results were reported for the VOC analyses demonstrating 

that method precision was in control. 

Elutriate and ambient seawater measurement precision 

Elutriate and ambient seawater analysis precision was evaluated using matrix duplicates for inorganic 

parameters and matrix spike duplicates or LCS duplicates for organic parameters. RPD objectives for this 

project ranged from 20 to 50% for matrix spike duplicates (depending on the parameter) and 20% for matrix 

duplicates and LCS duplicates. In general, the RPD criteria were met for all parameters. The only precision 

(RPD) deviations were noted for Pb and Ag measurements in ambient seawater. 

Tissue measurement precision 

Tissue analysis precision was evaluated using matrix duplicates for metals and matrix duplicates and LCS 

duplicates for PAHs. RPD objectives for this project were 20% for metals and 35% for PAHs. The RPD 

criteria were met for all parameters with four exceptions. For Nereis virens, the RPD for Zn exceeded the 

matrix duplicate criterion and the RPDs for naphthalene, 2-methylnaphthalene, and 1-methylene exceeded the 

matrix spike duplicate criterion. 

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6.2.4 Data accuracy 

Accuracy was evaluated using several QC sample types by calculating the percent recovered for each 

parameter of interest. A recovery value of 100% corresponds to 100% accuracy in this analysis. LCS and 

matrix spiked samples were incorporated as accuracy QC samples. Additionally, surrogate spikes were used 

to evaluate the accuracy of organic measurements and certified reference matrices (CRMs) were included in 

the tissue analysis program. 

6.2.4.1 Sediment analysis accuracy 

Percent recovery objectives for sediment measurements ranged from 50 to 140% for LCSs (depending on the 

parameter); 30 to 140% for matrix spikes (depending on the parameter); and 30 to 150% for surrogates. In 

most cases accuracy measurements were excellent. The few cases where deviations from the QAPPspecified accuracy goals occurred are summarized below. 

Percent recoveries for Sb for the matrix spike analyses performed on the Rapid TAT (Phase 1) sediments 

and the Phase 2 sediments fell below the QC acceptance criterion. However, the most significant 

interferences observed for Sb were associated with Phase 1 measurements and so project conclusions 

(based on Phase 2 findings) are not affected. 

Percent recoveries for cyanide matrix spikes performed on the Rapid TAT (Phase 1) sediments fell below 

the QC acceptance criterion. The low recoveries were most likely due to matrix interferences. Positive 

and nondetect cyanide results for the Rapid TAT (Phase 1) sediments should be considered estimated 

values with a low bias. 

The percent recovery for total phosphorus for one of the matrix spike analyses performed on a Phase 2 

sediment sample fell below the QC acceptance criterion. Positive and nondetect phosphorus results for 

the Phase 2 sediments should be considered estimated values with a low bias. 

Two Rapid TAT (Phase 1) samples, SC-123B and SB11L1, exhibited low surrogate recoveries for the 

PAH analyses. Positive and nondetect PAH results for these samples should be considered estimated 

values with a low bias. Surrogate recoveries were low for one Phase 2 sediment sample (SB12L2) for 

the pesticide and PCB analyses. As a corrective action measure, the sample was re-extracted and 

re-analyzed for these compounds. Although the re-analysis was 18 days beyond the QAPP-specified 

hold time, the surrogate recovery was acceptable and PCB and pesticide results were comparable to the 

initial data, indicating that the initial surrogate recovery problem may have been isolated to the spiking 

exercise and that the PCB and pesticide results are accurate. 

6.2.4.2 Elutriate and ambient seawater analysis accuracy 

Percent recovery objectives for aqueous measurements ranged from 50 to 120% for LCSs (depending on the 

parameter); 50 to 120% for matrix spikes (depending on the parameter); and 30 to 150% for surrogates. All 

percent recoveries for the LCSs and matrix spikes associated with the ambient seawater samples met the 

QAPP-specified QC acceptance criteria. A few elutriate accuracy thresholds were exceeded as summarized 

below. 

Low recoveries were observed for Cu, Be, and Zn for the matrix spike analyses in the elutriates. The 

positive and nondetect results for these metals should be considered estimated with a low bias. 

One elutriate sample, SB7U2EA, exhibited low surrogate recovery for the pesticide analysis. The positive 

and nondetect pesticide results in this sample should be considered estimated with a low bias. 

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The percent recoveries for several PCB compounds for the matrix spike and LCS analyses performed for 

the modified elutriates exceeded control limits. Results were unaffected in this case since the recoveries 

indicate a high bias and only nondetects were reported for PCBs. 

The percent recoveries for sulfide matrix spike analyses performed for the elutriates were 3% and 68% 

and laboratory personnel indicated that these low recoveries were related to sample interferences. 

Although batch LCSs met the specified accuracy criteria, nondetect results for elutriate samples 

SB7U2EA, SB9U2EA, SB9U2EB, C3L2EA, and C4L2EA should be considered suspect. Positive and 

nondetect results reported for sulfide in the remaining standard elutriates should be considered estimated 

values with a low bias. These results, however, are not considered critical to the overall project 

conclusions because sulfide concerns were not identified in the sediments and good survivorship was 

observed within the complementary SPP bioassays. 

6.2.4.3 Tissue analysis accuracy 

LCSs, matrix spikes, and CRMs were used to assess the accuracy of the tissue chemical measurements. The 

CRMs analyzed for metals were “DOLT-2” and “DORM-3” composed of dogfish liver and dogfish muscle, 

respectively. 

In general, the QAPP specified percent recoveries for LCSs, matrix spikes, and CRMs were met for all 

parameters and the tissue data are considered to be very accurate. The few cases where QAPP-specified 

accuracy goals were not met are summarized below. 

Several Hg matrix spike recovery thresholds for Nereis virens and Macoma nasuta analyses fell slightly 

below the control limits. The matrix spike recoveries for Zn in the Nereis virens analyses fell outside 

control limits. 

The percent recovery for Pb for just one of the analyses of DOLT-3 exceeded the control limits. Other 

QC samples associated with the batch (i.e., DORM-2 and matrix spike) yielded acceptable recoveries 

demonstrating that the method was in control. 

PAH surrogate recoveries were high for Nereis virens sample SB7UNV1. The positive and nondetect 

PAH results in this sample should be considered estimated with a high bias. 

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7.0 References 

APHA, 1992. Standard Methods for the Examination of Water and Wastewater, Eighteenth Edition; American 

Public Health Association; Washington, DC 1992. 

ASTM, 1994. ASTM Standards Volume 4.08 Soil and Rock (I): D 420- D4914, Section 4, Construction edition. 

American Society for Testing and Materials, Philadelphia, PA 1994. 

Bridges, Todd S., J. Daniel Farrar, B. Maurice Duke, 1997. The Influence of Food Ration on Sediment Toxicity 

in Neanthes arenaceodentata. Env. Toxicol. Chem. 16: 1659-1665. 

Bridges, Todd, 2006. Personal Communication. Telephone communication February 14th, 2006 with Dion 

Lewis.

Buchman, M.R., 1999. NOAA Screening Quick Reference Tables, NOAA HAZMAT report 99-1, Seattle WA, 

Coastal Protection and Restoration Division, National Oceanic and Atmospheric Administration, 12 pages. 

Carr, R. Scott, E.R. Long, H.L. Windom, D. C. Chapman, G. Thursby, G. M. Sloane, and D.A. Wolfe, 1996. 

Sediment Quality Assessment Studies of Tampa Bay, Florida, Environmental Toxicology and Chemistry. 

15 (7) 1218-1231. 

DeWitt, T.H., M.R. Pinza, L.A. Niewolny, V.I. Cullinan, and B.D. Gruendell, 1997. Development and 

evaluation of standard marine/estuarine chronic sediment toxicity test method using Leptocheirus 

plumulosus. Prepared for the U.S. Environmental Protection Agency, Office of Science and Technology. 

PNNL-11768. Pacific Northwest National Laboratory, Richland, WA. 

EPA, 1983. Methods for Chemical Analysis of Water and Wastes; U.S. EPA Office of Research and 

Development, Cincinnati, OH, March, 1983. 

EPA, 1986. Determination of Total Organic Carbon in Sediment; USEPA Region II Environmental Services 

Division Monitoring Management Branch; Edison, NJ. Lloyd Kahn, QA Specialist, 7/10/86. 

EPA and USACE, 1991. Evaluation of Dredged Material Proposed for Ocean Disposal—Testing Manual. 

EPA-503/8-91/001. 

EPA and USACE, 1993. Regional Implementation Manual. Requirements and Procedures for Evaluation of 

the Ocean Disposal of Dredged Material in Southeastern Atlantic and Gulf Coastal Waters. May 1993. 

EPA, 1995. CRITFC exposure study. Water Quality Criteria and Standards Newsletter. January 1995. EPA823-N-95-001 P 7. 

EPA, 1996. Test Methods for Evaluating Solid Wastes, SW-846: Washington DC. 

EPA and USACE, 1998. Evaluation of Dredged Material Proposed for Discharge in Waters of the U.S.—

Testing Manual. EPA-823-B-98-004. 

EPA, 1999. National Recommended Water Quality Criteria-Correction. Office of Water. EPA 822-Z-99-001. 

EPA, 2001. Method for Assessing the Chronic Toxicity of Marine and Estuarine Sediment-associated 

Contaminants with the Amphipod Leptocheirus plumulosus-First Edition. EPA 600/R-01/020. March 2001. 

Q:\mw97\Projects\01231021\0049\All_Final.doc 7-1 July 2006

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
EPA, 2002. Methods for Measuring the Acute Toxicity of Effluents to Freshwater and Marine Organisms. Fifth 

Edition. EPA-821-R-02-012. 

ENSR, 2005. Field Sampling Plan and Quality Assurance Project Plan Supporting Casotte Landing Slip 

Dredged Material CWA/MPRSA Suitability Testing. 

Goodwin and Associates, 2005. Phase I Cultural Resources Survey and Archeological Inventory of the 

Proposed Casotte Landing Natural Gas Import Terminal Project (Casotte Landing), Jackson County, 

Mississippi. Draft Report May 2005. 

Jarvinen, Alfred W. and Gerald T. Ankley, 1999. Linkage of Effects to Tissue Residues: Development of a 

Comprehensive Database for Aquatic Organisms Exposed to Inorganic and Organic Chemicals. SETAC 

Press. 

Lake, J., N. Rubinstein, H. Lee II, C. Lake, J. Heltshe and S. Pavignano, 1990. Equilibrium partitioning and 

bioaccumulation of sediment-associated contaminants by infaunal organisms. Environ. Toxicol. Chem. 

9:1095-1106. 

Long, E.R. and D.D. MacDonald, 1998a. Perspective: Recommended Uses of Empirically Derived, Sediment 

Quality Guidelines for Marine and Estuarine Ecosystems. Human and Ecological Risk Assessment. 4 (5) 

1019-1039. 

Long, E.R., L. Jay Field, and D.D. MacDonald, 1998b. Predicting Toxicity in Marine Sediments with Numerical 

Sediment Quality Guidelines. Environmental Toxicology and Chemistry. 17 (4) 714-727. 

Mississippi Department of Environmental Quality, 2003. State of Mississippi Water Quality Criteria for 

Intrastate, Interstate and Coastal Waters. Office of Pollution Control, Jackson, MS. 

Nakashima, S., R.E. Sturgeon, S.N. Willie, and S.S. Berman, 1988. Anal. Chim. Acta. (207) p 291. 

NOAA, 1993. Sampling and analytical methods of the National Status and Trends program National Benthic 

Surveillance and Mussel Watch Projects, 1984-1992. G.G. Lauenstein and A.Y. Cantillo, eds. Published by 

U.S. Dept. of Commerce, NOAA, National Ocean Service, Office of Ocean Resources Conservation and 

Assessment, Coastal Monitoring and Bioeffects Assessment Division, Silver Spring, MD, 1993. 

NOAA, 1986, 1987, 1989, 1990, 1991, 1996. National Status and Trends Database. 

http://ccmaserver.nos.noaa.gov/NSandT/NSandTdata.html 

Pinza, M.R., H.L. Mayhew, and J.Q. Word, 1996. Evaluation of older bay mud sediment from Richmond 

Harbor, California. PNNL-11318/UC-000. San Francisco: U.S. Army Corps of Engineers, San Francisco 

District. 

PSEP, 1995. Recommended Guidelines for Conducting Laboratory Bioassays on Puget Sound Sediments. 

Puget Sound Estuary Program. US Environmental Protection Agency, Region 10, Seattle, Washington. 

Rubinstein, N.I., J. Lake, F. Pruell, H. Lee II, B. Taplin, J. Heltshe, R. Bowen and S. Pavignano, 1987. 

Predicting bioaccumulation of sediment-associated organic contaminants: Development of a regulatory tool for 

dredged material evaluation. EPA 600/X-87/368. U.S. Environmental Protection Agency, Narragansett, RI. 

Singh, A., Singh, A.K. and R.W. Maichle, 2004. ProUCL Version 3.0 User Guide. USEPA. EPA/660/R04/079, 

April 2004. 

Q:\mw97\Projects\01231021\0049\All_Final.doc 7-2 July 2006

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Sullivan, Charles L., 1985. The Mississippi Gulf Coast: Portrait of a People. Windsor Publications, Northridge, 

California. 

URS Corporation, 2005a. Pascagoula LNG Environmental Site Assessment Revised Draft Report – Former 

Corning Area. February 2005. 

URS Corporation, 2005b. Reconnaissance Geotechnical Investigation Report – Phase I. Casotte Landing 

LNG Terminal, Pascagoula, MS. Draft Report. 

USACE, 1998. Section 103 Evaluation Brunswick Harbor Deepening Navigation Project. Environmental 

Resources Branch Planning Division. U.S. Army Engineer District, Savannah. March 1998. 40 p. 

USACE, 2002. Environmental Residue Effects Database (ERED). Webdate Novermber 4, 1997; updated 

October 1, 2002. http://www.wes.army.mil/el/ered/ 

Watras, C.J., and J.W. Huckabee, 1994. Mercury Pollution: Integration and Synthesis. CRC Press, Inc. ISBN 

1-56670-066-3. 

Word J., S. Bodensteiner, and L.S. Word, 2001. Results from Biological and Chemical Evaluation of Sediment 

Testing in Bahia Lagoon, CA. Report prepared for the Bahia Homeowners Association by Weston Solutions, 

Port Gamble, Washington. 

Word J., W.W. Gardiner, and D.W. Moore, 2005. Influence of Confounding Factors on SQGs and Their 

Application to Estuarine and Marine Sediment Evaluations. In: Use of Sediment Quality Guidelines and 

Related Tools for the Assessment of Contaminated Sediments. Edited by R.J. Wenning, G.E. Batley, 

C.G. Ingersoll, and D.W. Moore. Society of Toxicology and Chemistry. Pensacola, Florida. 

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Attachment 1 

Amphipod Evaluation Transmittal 27 March 2006 

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Attachment 2 

Water Column Evaluations, Numerical Model (STFATE) Input 

Parameters 

Provided by USEPA, Region 4 

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Pascagoula ODMDS

STFATE Modeling Zones

Zone A

Zone B

Zone C

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Water Column Evaluations 

Numerical Model (STFATE) Input Parameters 

Pascagoula ODMDS Zone A 

SITE DESCRIPTION

Parameter Value Units

Number of Grid Points (left to right) 45 

Number of Grid Points (top to bottom) 45 

Spacing Between Grid Points (left to right) 500 ft 

Spacing Between Grid Points (top to bottom) 500 ft 

Constant Water Depth 44 ft 

Roughness Height at Bottom of Disposal Site .0051 ft 

Slope of Bottom in X-Direction 0 Deg. 

Slope of Bottom in Z-Direction 0 Deg. 

Number of Points in Ambient Density Profile Point 2 

Ambient Density at Depth = 5 ft 1.0174 g/cc 

Ambient Density at Depth = 44 ft 1.0230 g/cc 

AMBIENT VELOCITY DATA

Parameter Value Units

Profile 2-Point at constant depth 

X-Direction Velocity at Depth = 10 ft -0.232 ft/sec 

Z-Direction Velocity at Depth = 10 ft -0.232 ft/sec 

X-Direction Velocity at Depth = 40 ft -0.116 ft/sec 

Z-Direction Velocity at Depth = 40 ft +0.116 ft/sec 

DISPOSAL OPERATION DATA

Parameter Value Units

Location of Disposal Point from Top of Grid 8,5002 ft 

Location of Disposal Point from Left Edge of Grid 8,2002 ft 

Dumping Over Depression 0 

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INPUT, EXECUTION AND OUTPUT

Parameter Value Units

Location of the Upper Left Corner of the Disposal Site 

- Distance from Top Edge 

2,000 ft 

Location of the Upper Left Corner of the Disposal Site 

- Distance from Left Edge 

2,000 ft 

Location of the Lower Right Corner of the Disposal Site 

- Distance from Top Edge 

21,500 ft 

Location of the Lower Right Corner of the Disposal Site 

- Distance from Left Edge 

20,500 ft 

Duration of Simulation 14,400 sec 

Long Term Time Step 600 sec 

COEFFICIENTS

Parameter Keyword Value

Settling Coefficient BETA 0.0001

Apparent Mass Coefficient CM 1.0001

Drag Coefficient CD 0.5001

Form Drag for Collapsing Cloud CDRAG 1.0001

Skin Friction for Collapsing Cloud CFRIC 0.0101

Drag for an Ellipsoidal Wedge CD3 0.1001

Drag for a Plate CD4 1.0001

Friction Between Cloud and Bottom FRICTN 0.0101

4/3 Law Horizontal Diffusion Dissipation Factor ALAMDA 0.0011

Unstratified Water Vertical Diffusion Coefficient AKYO Pritchard Expression 

Cloud/Ambient Density Gradient Ratio GAMA 0.2501

Turbulent Thermal Entrainment ALPHAO 0.2351

Entrainment in Collapse ALPHAC 0.1001

Stripping Factor CSTRIP 0.0031

1

Model default value 

2

Represents center of zone A. Dredged material requiring disposal in another location in order to 

meet the dilution criteria must be brought to the attention of EPA and the COE. 

Typical dilution achieved after 4 hours = 500:1 

Plume does not reach site boundaries within 4 hours 

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bottom

Z - Direction: Grid Spacing =500ft, 45 grids

X - Direction: Grid Spacing = 500ft, 45 grids

x

Current Velocity:

0.328fps @surface

0.164fps @bottom

X=2,000 ft

Z=2,000 ft

X=21,500

Z=20,500

Pascagoula ODMDS

Zone A

Disposal Location

(x=8,500ft:z=8,200)

surface bottom

actual ODMDS boundary

model site boundary

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Water Column Evaluations 

Numerical Model (STFATE) Input Parameters 

Pascagoula ODMDS Zone B 

SITE DESCRIPTION

Parameter Value Units

Number of Grid Points (left to right) 45 

Number of Grid Points (top to bottom) 45 

Spacing Between Grid Points (left to right) 600 ft 

Spacing Between Grid Points (top to bottom) 600 ft 

Constant Water Depth 46 ft 

Roughness Height at Bottom of Disposal Site .0051 ft 

Slope of Bottom in X-Direction 0 Deg. 

Slope of Bottom in Z-Direction 0 Deg. 

Number of Points in Ambient Density Profile Point 2 

Ambient Density at Depth = 5 ft 1.0174 g/cc 

Ambient Density at Depth = 46 ft 1.0230 g/cc 

AMBIENT VELOCITY DATA

Parameter Value Units

Profile 2-Point at constant depth 

X-Direction Velocity at Depth = 10 ft -0.232 ft/sec 

Z-Direction Velocity at Depth = 10 ft -0.232 ft/sec 

X-Direction Velocity at Depth = 40 ft -0.116 ft/sec 

Z-Direction Velocity at Depth = 40 ft +0.116 ft/sec 

DISPOSAL OPERATION DATA

Parameter Value Units

Location of Disposal Point from Top of Grid 13,5002 ft 

Location of Disposal Point from Left Edge of Grid 14,5002 ft 

Dumping Over Depression 0 

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
INPUT, EXECUTION AND OUTPUT

Parameter Value Units

Location of the Upper Left Corner of the Disposal Site 

- Distance from Top Edge 

2,000 ft 

Location of the Upper Left Corner of the Disposal Site 

- Distance from Left Edge 

2,000 ft 

Location of the Lower Right Corner of the Disposal Site 

- Distance from Top Edge 

25,000 ft 

Location of the Lower Right Corner of the Disposal Site 

- Distance from Left Edge 

27,000 ft 

Duration of Simulation 14,400 sec 

Long Term Time Step 600 sec 

COEFFICIENTS

Parameter Keyword Value

Settling Coefficient BETA 0.0001

Apparent Mass Coefficient CM 1.0001

Drag Coefficient CD 0.5001

Form Drag for Collapsing Cloud CDRAG 1.0001

Skin Friction for Collapsing Cloud CFRIC 0.0101

Drag for an Ellipsoidal Wedge CD3 0.1001

Drag for a Plate CD4 1.0001

Friction Between Cloud and Bottom FRICTN 0.0101

4/3 Law Horizontal Diffusion Dissipation Factor ALAMDA 0.0011

Unstratified Water Vertical Diffusion Coefficient AKYO Pritchard Expression 

Cloud/Ambient Density Gradient Ratio GAMA 0.2501

Turbulent Thermal Entrainment ALPHAO 0.2351

Entrainment in Collapse ALPHAC 0.1001

Stripping Factor CSTRIP 0.0031

1

Model default value 

2

Represents center of zone A. Dredged material requiring disposal in another location in order to 

meet the dilution criteria must be brought to the attention of EPA and the COE. 

Typical dilution achieved after 4 hours = 500:1 

Plume does not reach site boundaries within 4 hours 

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
bottom

Z - Direction: Grid Spacing =600ft, 45 grids

X - Direction: Grid Spacing = 600ft, 45 grids

x

Current Velocity:

0.328fps @5ft

0.164fps @ 40ft

X=2,000 ft

Z=2,000 ft

X=25,000

Z=27,000

Pascagoula ODMDS

Zone B

Disposal Location

(x=13,500ft :z=14,500)

surface bottom

actual ODMDS boundary

model site boundary

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Water Column Evaluations 

Numerical Model (STFATE) Input Parameters 

Pascagoula ODMDS Zone C 

SITE DESCRIPTION

Parameter Value Units

Number of Grid Points (left to right) 45 

Number of Grid Points (top to bottom) 45 

Spacing Between Grid Points (left to right) 400 ft 

Spacing Between Grid Points (top to bottom) 600 ft 

Constant Water Depth 47 ft 

Roughness Height at Bottom of Disposal Site .0051 ft 

Slope of Bottom in X-Direction 0 Deg. 

Slope of Bottom in Z-Direction 0 Deg. 

Number of Points in Ambient Density Profile Point 2 

Ambient Density at Depth = 5 ft 1.0174 g/cc 

Ambient Density at Depth = 47 ft 1.0230 g/cc 

AMBIENT VELOCITY DATA

Parameter Value Units

Profile 2-Point at constant depth 

X-Direction Velocity at Depth = 10 ft -0.232 ft/sec 

Z-Direction Velocity at Depth = 10 ft -0.232 ft/sec 

X-Direction Velocity at Depth = 40 ft -0.116 ft/sec 

Z-Direction Velocity at Depth = 40 ft +0.116 ft/sec 

DISPOSAL OPERATION DATA

Parameter Value Units

Location of Disposal Point from Top of Grid 9,6602 ft 

Location of Disposal Point from Left Edge of Grid 11,2002 ft 

Dumping Over Depression 0 

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
INPUT, EXECUTION AND OUTPUT

Parameter Value Units

Location of the Upper Left Corner of the Disposal Site 

- Distance from Top Edge 

2,000 ft 

Location of the Upper Left Corner of the Disposal Site 

- Distance from Left Edge 

2,000 ft 

Location of the Lower Right Corner of the Disposal Site 

- Distance from Top Edge 

25,000 ft 

Location of the Lower Right Corner of the Disposal Site 

- Distance from Left Edge 

15,800 ft 

Duration of Simulation 14,400 sec 

Long Term Time Step 600 sec 

COEFFICIENTS

Parameter Keyword Value

Settling Coefficient BETA 0.0001

Apparent Mass Coefficient CM 1.0001

Drag Coefficient CD 0.5001

Form Drag for Collapsing Cloud CDRAG 1.0001

Skin Friction for Collapsing Cloud CFRIC 0.0101

Drag for an Ellipsoidal Wedge CD3 0.1001

Drag for a Plate CD4 1.0001

Friction Between Cloud and Bottom FRICTN 0.0101

4/3 Law Horizontal Diffusion Dissipation Factor ALAMDA 0.0011

Unstratified Water Vertical Diffusion Coefficient AKYO Pritchard Expression 

Cloud/Ambient Density Gradient Ratio GAMA 0.2501

Turbulent Thermal Entrainment ALPHAO 0.2351

Entrainment in Collapse ALPHAC 0.1001

Stripping Factor CSTRIP 0.0031

1

Model default value 

2

Represents center of zone A. Dredged material requiring disposal in another location in order to 

meet the dilution criteria must be brought to the attention of EPA and the COE. 

Typical dilution achieved after 4 hours = 500:1 

Plume does not reach site boundaries within 4 hours 

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bottom

Z - Direction: Grid Spacing =400ft, 45 grids

X - Direction: Grid Spacing = 600ft, 45 grids

x

Current Velocity:

0.328fps @5ft

0.164fps @ 40ft

X=2,000 ft

Z=2,000 ft

X=25,000

Z=15,800

Pascagoula ODMDS

Zone C

Disposal Location

(x=9,660ft:z=11,200)

surface bottom

actual ODMDS boundary

model site boundary

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Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Appendix E

Appendices: 

A Field Logs 

B Grain Size Data 

C Chemistry Data 

D Toxicity Laboratory Data 

E Ancillary Project Data 

F Input and Output Files 

This information is too voluminous to include in this EIS. Bayou Casotte Energy has filed its 

Section 103 evaluation with the U.S. Army Corps of Engineers who will in turn coordinate 

with the U.S. Environmental Protection Agency. 

 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX E2 

DREDGED MATERIAL MANAGEMENT PLAN 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
BAYOU CASOTTE ENERGY LLC 

CASOTTE LANDING 

NATURAL GAS IMPORT 

TERMINAL PROJECT 

DREDGED MATERIAL MANAGEMENT 

PLAN

JULY, 2006

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Prepared for: 

Bayou Casotte Energy LLC 

1500 Louisiana Street 

Houston, Texas 77002 

Dredged Material Management Plan 

ENSR Corporation 

July, 2006 

Document No.: 01231-021-0041 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
i July 2006

Contents

List of Acronyms and Abbreviations...............................................................................................................1

Executive summary......................................................................................................................................ES-1

1.0 Introduction............................................................................................................................................... 1-1

1.1 Scope............................................................................................................................................... 1-1

1.2 Project dredging requirement.......................................................................................................... 1-2

1.3 History of site................................................................................................................................... 1-2

1.4 Prior studies and reports................................................................................................................. 1-2

2.0 Navigational requirements...................................................................................................................... 2-1

2.1 Federal channels............................................................................................................................. 2-1

2.2 Project slip ....................................................................................................................................... 2-2

3.0 Description of dredged material ............................................................................................................ 3-1

3.1 Initial dredging ................................................................................................................................. 3-1

3.1.1 Physical description........................................................................................................... 3-1

3.1.2 Suitability characterization................................................................................................. 3-2

3.2 Maintenance dredging..................................................................................................................... 3-2

4.0 Recommended dredging and placement plan..................................................................................... 4-1

4.1 Dredging Equipment Options.......................................................................................................... 4-1

4.2 Dredged material placement options.............................................................................................. 4-1

4.3 Initial (new work) dredging .............................................................................................................. 4-4

4.3.1 Ocean Dredged Material Disposal Site............................................................................. 4-4

4.3.2 Beneficial use sites............................................................................................................ 4-4

4.4 Maintenance dredging..................................................................................................................... 4-5

5.0 Dredging operations................................................................................................................................ 5-1

5.1 Dredging equipment........................................................................................................................ 5-1

5.1.1 Mechanical dredges .......................................................................................................... 5-1

5.1.2 Hydraulic dredges.............................................................................................................. 5-2

5.2 Initial Project dredging..................................................................................................................... 5-3

5.2.1 Slip dredging sequence..................................................................................................... 5-3

5.2.2 Timing................................................................................................................................. 5-3

5.2.3 Placement .......................................................................................................................... 5-4

5.2.4 Mitigation measures........................................................................................................... 5-4

5.2.5 Environmental Protection .................................................................................................. 5-4

5.3 Maintenance dredging..................................................................................................................... 5-4

6.0 References ................................................................................................................................................ 6-1 

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List of Tables 

Table 3-1 Generalized Dredge Material Types by Elevation (URS, 2005) .................................................. 3-1

List of Figures 

Figure 1-1 Overview of the proposed facility............................................................................................. 1-1

Figure 1-2 Project slip and Bayou Casotte Channel................................................................................. 1-4

Figure 1-3 Historic shoreline ...................................................................................................................... 1-5

Figure 2-1 Federal channel system ........................................................................................................... 2-1

Figure 4-1 Dredged material placement alternatives................................................................................ 4-2

Figure 4-2 Conceptual beneficial use projects .......................................................................................... 4-3

Figure 5-1 Typical clamshell dredge with disposal scow (MNI, 2005) ..................................................... 5-1

Figure 5-2 Typical backhoe (excavator) dredged (MNI, 2005)................................................................. 5-2

Figure 5-3 Typical cutterhead hydraulic dredge........................................................................................ 5-2

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LIST OF ACRONYMS AND ABBREVIATIONS 

BCDMMS Bayou Casotte Dredged Material Management Site 

Bgs Below ground surface 

BU Beneficial Use 

CDF Confined Disposal Facility 

CWA Clean Water Act 

DEIS Draft Environmental Impact Statement 

DM Dredged material 

DMMP Dredged Material Management Plan 

EIS Environmental Impact Statement 

EPA Environmental Protection Agency 

ESA Environmental Site Assessment 

FERC Federal Energy Regulatory Commission 

FSP Field Sampling Plan 

GPS Global positioning system 

LNG Liquefied natural gas 

mcy Million cubic yards 

ODMDS Ocean Dredged Material Disposal Site 

MCP Mississippi Coastal Program 

MLLW Mean Lower Low Water 

MDEQ Mississippi Department of Environmental Quality 

MDMR Mississippi Department of Marine Resources 

MPRSA Marine Protection Research and Sanctuaries Act 

QAPP Quality Assurance Project Plan 

SAP Sampling and Analysis Plan 

SMA Special Management Area 

TSS Total suspended solids 

USACE U.S. Army Corps of Engineers 

WRDA Water Resources Development Act 

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Executive summary 

This Dredged Material Management Plan (DMMP) describes the dredging requirements, dredged material, 

operations, and recommended placement plan for the proposed onshore liquefied natural gas (LNG) import 

terminal and associated facilities located south of the existing Chevron, USA (CUSA) Pascagoula Refinery on 

Bayou Casotte, just east of Pascagoula, Mississippi in Jackson County. The proposed Casotte Landing 

Natural Gas Import Terminal Project includes construction of a slip and berth for offloading LNG carriers, 

relocation of existing Refinery Berths 6 and 7, and construction of facilities to receive and regasify LNG for 

transport into the nearby existing United States natural gas transmission grid. This project is described in 

detail in the Draft Environmental Impact Statement (DEIS) prepared by the Federal Energy Regulatory 

Commission, May 2006. This DMMP serves as supporting information for permitting by federal and state 

agencies. 

Construction of the proposed slip will require dry excavation of approximately 1 Million cubic yards of material, 

to be used for site development and dredging of approximately 3.5 Million cubic yards of material to a depth of 

46 feet below MLLW (42 feet required plus 2 feet advanced maintenance plus 2 feet allowable overdepth). 

The dredged material is composed of layers of sand and clay. Dredging also includes deepening Bayou 

Casotte between the existing federal navigation channel and the slip. 

Placement alternatives for the dredged material were evaluated in the DEIS. The preferred placement site is 

the Pascagoula Ocean Dredged Material Disposal Site (ODMDS) located approximately 11 nautical miles 

offshore in the Gulf of Mexico. Dredged material sampling and characterization was recently completed to 

determine its suitability for disposal at the ODMDS. Material will be removed using mechanical dredging 

methods and transported via scows to the ODMDS. Beneficial use of the dredged material, including 

shoreline and wetland restoration, has been investigated extensively by the Corps of Engineers and the 

Mississippi Department of Marine Resources. The known beneficial use sites have limited capacity and will be 

considered for placement of a portion of the material if they are available at the time of project construction. It 

is estimated that dredging and placement operations will take 4 to 6 months. 

After completion of the project, the slip area will shoal in at a rate of approximately 250,000 cubic yards per 

year which will require periodic removal to maintain the required 42-foot depth. Experience gained after the 

initial project is completed will determine the frequency of maintenance dredging. The preferred placement 

site for maintenance material is the ODMDS. As is the case with the slip construction, placement at beneficial 

reuse sites will be investigated when needed. 

At this time there are no seasonal restrictions on dredging or placement. Model studies have shown that 

resuspension of material from dredging operations did not result in water column TSS concentrations 

significantly higher than those observed in Bayou Casotte. Dredging plans and specifications will incorporate 

any permit requirements and conditions and include contingency plans to ensure compliance. 

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1.0 Introduction

Bayou Casotte Energy LLC (Bayou Casotte Energy), a subsidiary of Chevron U.S.A. Inc. (CUSA), proposes to 

build and operate an onshore liquefied natural gas (LNG) import terminal and associated facilities (Terminal) 

south of the existing CUSA Pascagoula Refinery (Pascagoula Refinery) on Bayou Casotte, just east of 

Pascagoula, Mississippi in Jackson County. The proposed Casotte Landing Natural Gas Import Terminal 

Project (Casotte Landing, Project, or Terminal) includes construction of a slip and berth for offloading LNG 

carriers (LNGCs), relocation of existing Refinery Berths 6 and 7, and construction of facilities to receive and 

regasify LNG for transport into the nearby existing United States (U.S.) natural gas transmission grid. The 

Project is designed to process a nominal rate of 1.3 billion standard cubic feet per day (BSCFD). An overview 

of the proposed slip and berth can be seen in Figure 1-1. A more detailed project description is included in 

Draft Environmental Impact Statement (FERC, 2006) 

Figure 1-1 Overview of the proposed facility

1.1 Scope 

The Dredged Material Management Plan (DMMP) supplements the Draft Environmental Impact Statement 

(DEIS) for the Casotte Landing Natural Gas Import Terminal Project, prepared by the Federal Energy 

Regulatory Commission (FERC), May 2006, which describes alternative slip construction, excavation, and 

dredging methods for the Project slip. An initial draft DMMP was included in the Environmental Reports that 

served as the basis for the DEIS. Information from the DEIS is summarized in the DMMP where needed for 

clarity. 

As a marine terminal, the construction and maintenance of this facility will require a significant amount of 

dredging. The DMMP provides information pertaining to the dredging and placement of dredged material 

associated with the Project. The DMMP describes the volume, and other characteristics of the dredged 

material removed in connection with the initial construction (new work dredging) of the Project as well as the 

dredged material requiring removal as a result of sedimentation (maintenance dredging) that may occur over 

the course of the project life (MNI, 2005). 

The DMMP focuses on the dredging and material placement operations needed to complete the Project 

following the current preferred placement plan as described in the DEIS (Sect. 3.7). 

This DMMP updates the draft DMMP dated January 2006 (ENSR, 2006a) and will serve as supporting 

documentation for the Joint Application and Notification process, in particular, the Individual Permit issued by 

the U. S. Army Corps of Engineers (USACE) to comply with Section 10 of the Rivers and Harbors Act of 1899 

(33U.S.C. 403); Section 404 of the Clean Water Act (33 U.S.C. 1344; and Section 103 of the Marine 

Protection, Research, and Sanctuaries Act of 1972 (MPRSA), as amended) and associated requirements of 

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the Mississippi Department of Marine Resources (MDMR) and the Mississippi Department of Environmental 

Quality (MDEQ).

1.2 Project dredging requirement 

The Project includes the construction of a new double-berth slip for accommodation of an LNG Berth and the 

relocation of an existing refinery berth for the Pascagoula Refinery along the eastern shore of Bayou Casotte 

(Figure 1-2). The upper 10 to 14 feet of material (approximately 1 million cubic yards [mcy]) will be excavated 

via traditional earth moving equipment and will be used on-site for construction purposes. The remaining 

material below the water table will be mechanically dredged (approximately 3.5 mcy) and the material placed 

at a suitable site(s). 

1.3 History of site 

Before industry moved into the area around 1960, the proposed slip area was largely aquatic as depicted in 

Figure 1-3. During the 1950’s the slip area was filled, apparently with material dredged from Bayou Casotte as 

a way to establish what was then the largest industrial site in the state (Goodwin and Associates, 2005; C. 

Sullivan, 1985). The slip area and larger LNG terminal site were initially occupied by Corning Glass works 

(formerly Cohart Refractory), where high temperature brick was manufactured at the site until 1989 using a 

magnesite refractory process. 

1.4 Prior studies and reports 

A number of reports have been prepared by USACE and others to address dredging and its impacts on the 

area. Listed below are a few of the more significant reports that were used in the preparation of the DEIS and 

the DMMP for this project. 

Draft Environmental Impact Statement for Casotte Landing Natural Gas Import Terminal Project, Federal 

Energy Regulatory Commission, May 2006. FERC is the lead Federal agency for preparing the Environmental 

Impact Statement for the Casotte Landing Natural Gas Terminal project. Included in the Draft EIS (DEIS) are 

alternative analyses for the project including dredged material placement. The DEIS was issued on May 19, 

2006 by the FERC, with the public comment period scheduled through July 10, 2006. 

Casotte Landing Slip Sediment Evaluation Report, ODMDS Suitability, ENSR Corporation, June 2006. This 

report summarizes the field investigations and chemical and biological test results performed on the dredged 

material to be removed to create the project slip. This data and sediment characterization provides the basis 

for Corps and EPA decision making for placement at the Pascagoula Ocean Dredged Material Disposal Site 

(ODMDS).

Special Management Area Plan for the Port of Pascagoula, Jackson County, Mississippi, Ralph M. Field 

Associates, Inc., November 1985. The Mississippi Coastal Program (MCP) was developed to implement the 

Mississippi Coastal Wetlands Protection Law which was passed in 1973. The MCP designed the Special 

Management Area (SMA) Plan for the Port of Pascagoula as a result of a three-year-long planning process 

initiated in 1982 and which included numerous discussion and negotiation sessions, as well as field 

reconnaissance and technical studies by a SMA Task Force. The SMA was established to adopt 

management plans through cooperative and voluntary processes involving local, state, and federal agencies. 

The objective of this plan was to establish a balance among competing interests in coastal areas, taking into 

consideration the diverse ecological values of the wetlands, the need for maintaining industrial requirements, 

the importance of wetlands to the fisheries industries, and other factors. 

Environmental Impact Statement for the Designation of an Ocean Dredged Material Disposal Site Located 

Offshore Pascagoula, Mississippi, Robert Howard, July 1991. The Environmental Protection Agency (EPA) 

was the lead Federal agency for preparing the Environmental Impact Statement (EIS) for designation of a new 

Ocean Dredged Material Disposal Site (ODMDS) in the Gulf of Mexico south of Pascagoula, Mississippi. This 

report discusses the reasons why an Ocean Disposal site is needed outside of Pascagoula and the 

environmental requirements for placement of material at the ODMDS. 

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Dredged Material Management Plan, Pascagoula River Harbor, U.S. Army Corps of Engineers Mobile District, 

June 2003. This report addresses the disposal of material from the Pascagoula River Inner Harbor and a 

portion of the Upper Pascagoula Channel. The purpose of this report was to determine the best location for 

dredged material associated with the Pascagoula Channel. 

Dredged Material Management Plan for Maintenance of Bayou Casotte Inner Harbor Pascagoula Harbor,

Mississippi, U.S. Army Corps of Engineers Mobile District, January 2000. The dredged material management 

site for the Bayou Casotte Inner Harbor was at Greenwood Island. This site had been used for disposal of 

dredged material from the Bayou Casotte Inner Harbor since 1979. In the early 1990’s it was found to have 

elevated lead levels in the soil. The U. S. Army Corps of Engineers, Mobile District, determined that 

Greenwood Island was no longer a suitable disposal area. The replacement site is the Bayou Casotte Dredged 

Material Management Site (BCDMMS). This report constitutes the decision document justifying the 

construction of the BCDMMS. 

Chevron Products Company Pascagoula Refinery, Inland Testing Manual Tier I, Brown and Caldwell, 

December 2000. The Bayou Casotte Channel was proposed to be deepened from 38 feet to 42 feet and 

widened from 225 feet to 300 feet. The maintenance sediment from the Inner Bayou Casotte would be placed 

in a USACE permitted Confined Disposal Facility (CDF) to be constructed on the east shore of the Bayou 

Casotte mouth. This document has generated physical and chemical information about the sediment and 

surface water conditions in the Inner Bayou Casotte Harbor. 

Chevron Products Company Pascagoula Refinery, Sampling and Analysis Plan Tier II, Brown and Caldwell, 

December 2000. This document outlines the Sampling and Analysis Plan (SAP) efforts that will be followed in 

order to evaluate the quality of effluent from the Chevron Products Company – Pascagoula, MS Refinery’s 85-

acre upland Confined Disposal Facility (CDF) during active dredging operations. The evaluation provides 

information that is used to determine potential impacts associated with effluent water discharge from 

Chevron’s CDF to the receiving water during active dredge operations. 

Joint Application and Notification for New Work and Maintenance Dredging at Refinery Marine Terminal Bayou 

Casotte, Mississippi, Brown and Caldwell, 2001. This report discusses Chevron’s Products Company – 

Pascagoula, MS Refinery’s need to modify the dimensions of the approach to its refinery marine terminal 

facilities and to deepen the approaches. The proposed new work and maintenance sediment was hydraulically 

placed in the 85-acre upland Confined Disposal Facility (CDF) that Chevron Products Company – Pascagoula, 

MS Refinery has operated and maintained. 

Long-Term Comprehensive Master Plan for Beneficial Uses of Dredged Material Along Coastal Mississippi,

U.S. Army Corps of Engineers, Mobile District, September 2002. The Corps coordinated with state and local 

agencies to establish links between dredging projects and projects along three Mississippi coastal counties 

(Hancock, Harrison, and Jackson) that may be able to beneficially use the dredged materials to enhance or 

restore coastal habitats. 

Project Management Plan, Implementation of Comprehensive Master Plan for Beneficial Uses of Dredged 

Material Along Coastal Mississippi, U.S. Army Corps of Engineers, Mobile District, March 2003. This is the 

second phase of the Long-Term Comprehensive Master Plan. The objective of this plan is to prioritize the 

beneficial use sites and consider new sites not investigated previously. The report focuses on three of the 

most favorable projects for each of the three coastal counties. 

Reconnaissance Geotechnical Investigation Report – Phase I. Casotte Landing LNG Terminal, Pascagoula, 

MS. Draft Report. URS Corporation, 2005 This report provided information used to determine the general 

physical characteristics of site soils and sediments and estimates of the volumes of each type of material to be 

excavated and dredged from the project slip area. 

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Figure 1-2 Project slip and Bayou Casotte Channel 

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Figure 1-3 Historic shoreline 

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2.0 Navigational requirements 

Navigation to and from the Project will use the existing Federal navigation channels through the Mississippi 

Sound to the Bayou Casotte Channel. Figure 2-1 shows the federal channel system beginning at the Horn 

Island Pass Channel, through the Pascagoula Channel into the Bayou Casotte Channel to the Project slip. A 

detailed description of the LNG carrier transit in the Port of Pascagoula is included in the DEIS (Sect. 4.12.5). 

Ship simulation studies performed for the Project design have shown that modification to the Federal channels, 

including the existing turning basin adjacent to the Project, is not needed. 

Figure 2-1 Federal channel system 

2.1 Federal channels 

The existing Bayou Casotte channel project depths were authorized in 1986 by Section 202 (a) of the Water 

Resources Act of 1986 (WRDA86) (Public Law 99-662) which include modifications to the Federal navigation 

project for Pascagoula Harbor. The authorized dimensions are: Deepening and widening the Gulf Entrance 

Channel to 44 feet by 550 feet from the 44-foot depth contour in the Gulf of Mexico to the bend at the southern 

end of Horn Island Pass; and deepening and widening Horn Island Pass to 44 feet by 600 feet between the 

bends at the southern and northern ends of that pass, for a total distance of about 4-1/2 miles, and relocating 

the Horn Island Pass reach about 500 feet westward; Reconfiguring the impoundment basin in Horn Island 

Pass to provide a section within the channel limits 1,500 feet long with a total depth of 56 feet to facilitate 

maintenance, and allowing for future realignment of Horn Island Pass reach as natural conditions warrant; 

Deepening the Lower Pascagoula Channel to 42 feet from the bend at the northern end of Horn Island Pass, 

through Mississippi Sound; Widening and deepening the Bayou Casotte Channel to 42 feet by 350 feet from 

the junction with the main channel to the mouth of Bayou Casotte, a distance of about 3-1/2 miles; A turning 

basin 42 feet deep at the mouth of Bayou Casotte with a total turning diameter of 1,150 feet, including the 

channel width; Widening and deepening the Bayou Casotte Inner Harbor Channel above the turning basin to 

42 feet by 350 feet for a distance of about 1,200 feet; Bend easing and widening; and Mitigation for the 

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unavoidable loss of four acres of emergent wetlands by restoring six acres of disturbed wetland habitat south 

of the Greenwood Island DMMS to a more natural emergent nature. 

Records show that USACE began maintenance dredging of the Bayou Casotte channel in 1974. Disposal 

was not recorded but apparently was in open water in Mississippi Sound. Prior to the last improvement to 

bring the channel to its authorized dimensions, the maintenance dredging frequency of once every 36 months 

(3 years) was estimated. This would amount to about 310,000 cubic yards (cy) every 36 months. The 

maintenance dredging for the turning basin was estimated to be 209,300 cy every 36 months. (USACE, 2000) 

2.2 Project slip 

The Project slip will provide a double berth (a crude tanker berth for the refinery and a berth for the Project’s 

LNG tanker) and berthing for tugs (Figure 1-2). Because of its angled alignment with the Bayou Casotte 

Channel, the length of the slip varies from 1,450 to 2,150 feet (at a reference depth of -40 ft MLLW). The width 

will be approximately 900 feet. The side slopes of the slip will be 5:1 which is the angle of repose for the bank 

material. The final slopes will be protected from scour with riprap. 

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3.0 Description of dredged material 

This section summarizes the volume and other characteristics of the material to be dredged from the Project 

slip. These characteristics are important to the selection of dredging equipment and the placement of the 

dredged material. 

USACE currently defines dredging projects by two categories: initial (new work) and maintenance projects. 

New work projects are defined by projects that are original construction or deepening of existing projects. 

Maintenance dredging is work that takes place on a regular time frame to maintain the authorized depths of 

active projects. 

The initial dredging will be considered new work dredging by USACE. Construction of the proposed slip would 

involve excavation of the upper material and dredging of the underlying materials present at the site. The 

Project slip will be dredged to a depth of -46 ft MLLW (-42 ft required Project depth plus 2 ft advanced 

maintenance plus 2 ft overdepth) for the entrance to the LNG berth and ship slip area. 

Shoaling occurs naturally as suspended sediments within the channel settle into the berthing area. Periodic 

maintenance dredging would be required to maintain the navigable depth of the dredged slip of -42 ft MLLW. 

3.1 Initial dredging 

3.1.1 Physical description 

Based on the current slip design, dredged material volumes were estimated using geometric analysis. The 

volume estimates were based on average surface elevations taken from bathymetric and topographic surveys. 

The estimates do not take into account variations in the surface elevation throughout the dredge prism. The 

volumes are based on a dredged depth of 46 ft MLLW (-42 ft Project depth plus 2 ft advanced maintenance 

plus 2 ft allowable overdepth). Table 3-1 provides a summary of the generalized soil conditions. 

Table 3-1 Generalized Dredge Material Types by Elevation (URS, 2005) 

Soil Classification Elevation Range (ft MLLW) 

Fill and Surficial Sand +10 to 0 

Surficial Sand 0 to -7 

Upper clay -7 to -30 

Sandy Clay with Sand Seams -30 to -54 

A total volume of 4.5 million cubic yards (mcy) of excavated and dredged material has been estimated. The 

soil above 0 ft MLLW, about 1 mcy, will be excavated by traditional earthmoving equipment in the dry and 

used for facility construction purposes. The excavation and handling of this material is not covered in this 

DMMP. The remaining material, about 3.5 mcy, will be dredged and is described in this DMMP. 

The type of material being dredged has a significant impact on the dredging techniques selected, placement 

options, and cost of dredging. The material proposed for dredging and placement is primarily comprised of 

upper clay. Sandy clay with sand seams comprises the rest of the dredged material. (URS, 2005) 

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3.1.2 Suitability characterization 

A full study has been completed to characterize the dredged material in order to determine its suitability for the 

placement options under consideration (see Section 4). The study was designed in coordination with the 

relevant agencies (USACE, EPA and MDMR), who will make the final suitability determination. To determine 

suitability for placement at an offshore site, a full suite of testing was conducted as required by Marine 

Protection, Research and Sanctuaries Act (MPRSA) and specified in the Green Book (EPA/USACE, 1991). 

Sediment quality is currently being evaluated based on sediment chemistry and biological testing, including 

toxicity and bioaccumulation testing. Furthermore, water quality modeling has been conducted using the 

regulatory model STFATE (ENSR, 2006b) 

3.2 Maintenance dredging 

Upon completion of the initial (new work) dredging, a maintenance dredging program will need to commence 

to keep the slip at the required depth. Dredging will need to be performed on a regular basis to remove 

sediment that will be deposited in the slip by shoaling (sedimentation). The shoaling of the slip may be caused 

by upland runoff and shoreline erosion as well as large ships plowing sediments up the channel. The rate of 

shoaling is highly variable and depends largely on facility layout, marine storm events, and flows in the 

adjacent waterway from upland runoff. 

The preliminary volumetric sedimentation rates for the slip are estimated to be up to 250,000 cy/yr. The 

sedimentation in the slip is subject to a high degree of uncertainty and a more detailed sedimentation analysis 

is recommended to better plan for expected maintenance dredging needs. Annual condition surveys in the slip 

will determine the need for maintenance dredging before berthing is adversely impacted. With ongoing annual 

surveys, the maintenance cycle can be projected more accurately. 

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4.0 Recommended dredging and placement plan 

4.1 Dredging Equipment Options 

There are three main types of dredges: mechanical dredges, hopper dredges, and hydraulic dredges. 

Selection of the appropriate type of dredge is based on the properties of the material to be dredged and the 

logistics of dredged material placement for the Project. Generally the hopper dredge is used for offshore 

dredging, hydraulic dredge for nearshore, mechanical dredge for new work, and hydraulic/hopper dredge for 

maintenance (MNI, 2005). 

Mechanical and hydraulic dredging methods were considered and evaluated based on Project needs including 

placement requirements. Those methods suitable for use in the recommended plan for initial work and 

maintenance are described in more detail in Section 5. Hopper dredges are large, usually self propelled, and 

typically used for open ocean channel dredging. Due to the limited dimensions of the slip and potential 

adverse impacts to marine turtles, the Project will not use hopper dredges. 

4.2 Dredged material placement options 

Initially, the Project team researched work by others, primarily USACE and MDMR, to prepare a wide range of 

placement options to consider for the initial construction and for future maintenance needs. This list was then 

evaluated using a multi-tiered screening process. The results of the screening process and evaluation are 

described in the DEIS (Sect. 3.7). 

There are a number of placement options near the Bayou Casotte Harbor that consist of confined, upland 

confined, partially confined, and unconfined sites. Some of these sites are still actively used for placement of 

maintenance dredged material while others are currently out of use and even in private ownership. Some 

sites that may reuse the dredged material to create salt marsh, protect shorelines from erosion and other 

beneficial uses, are included (MNI, 2005). The placement sites within the Project vicinity are shown in Figure 

4-1.

The Project continues to evaluate potential beneficial uses of the dredged material. Several studies, jointly 

prepared by USACE and MDMR (USACE, 2002 and USACE, 2003), have evaluated numerous opportunities 

for beneficial use of dredged material. The availability of these sites has changed over the recent past and 

new sites may be added. Testing has been completed by Chevron that will support beneficial use placement 

suitability if sites become available prior to Project dredging. 

The following alternative plans for the initial dredging requirement of 3.5 mcy and expected maintenance 

dredging are described in more detail in the DEIS (Sect. 3.7). As described in Sect. 3.1.1 an additional 1 mcy 

of material above the water table, will be excavated from the surface of the slip area and used for on-site 

construction. The following alternative placement sites are shown on Figures 4-1 and 4-2. 

Preferred Option - Offshore placement and Beneficial Use – Approximately 3.5 mcy will be mechanically 

dredged, placed on disposal scows or barges and transported to the EPA’s designated Pascagoula Ocean 

Dredged Material Disposal Site (ODMDS) located approximately 11 nautical miles offshore in the Gulf of 

Mexico. A portion of the material would be available for beneficial use that may include the existing Round 

Island and Greenwood Island Restoration projects and the proposed South Wetlands Restoration project 

and/or future Beneficial Use projects that may become available prior to Project construction. This alternative 

may also serve as an option for future maintenance. This plan is described in more detail in Section 4.3 of this 

report.

Alternative 1 – New Upland Confined Disposal Facility – Two options were investigated: the North Woods site 

and a new property purchase. Detailed evaluation of these alternatives has been suspended and would be 

pursued only if the preferred plan, placement at ODMDS, is not permitted. 

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Figure 4-1 Dredged material placement alternatives 

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Figure 4-2 Conceptual beneficial use projects 

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This alternative is described in more detail in the DEIS (Sect. 3.7) and MNI, 2005. 

Alternative 2 – Permitted On-shore Disposal (Existing Landfills) - This alternative was considered for both initial 

construction and maintenance and was dropped from further consideration. This alternative is described in 

more detail in the DEIS (Sect. 3.7) and MNI, 2005. 

4.3 Initial (new work) dredging 

4.3.1 Ocean Dredged Material Disposal Site 

Based on an evaluation of advantages and disadvantages as described in the DEIS (Sect. 3.7), the 

Pascagoula ODMDS is considered to be the best alternative for placement of the initial (new work) dredged 

material from the proposed Project. In its EIS for designation of the ODMDS, the EPA concluded that impacts 

associated with placement of dredged materials in the site would be localized to the vicinity of the placement 

site and would not result in significant adverse effects to the environment (FERC, 2006). 

4.3.2 Beneficial use sites 

Opportunities may exist for placement of a portion of the material at a beneficial use site which would reduce 

the volume to be placed at ODMDS. At this time, the sites considered are: Round Island and Greenwood 

Island restoration projects and the proposed South Wetlands Restoration project. The combined total capacity 

of these three beneficial use sites is very limited (less than 1 mcy). The capacity of these sites is based on 

studies completed prior to hurricane Katrina. It is likely that the sites listed here will require additional material 

and new coastal or barrier island sites requiring protection will emerge as post-Katrina conditions are 

evaluated. 

4.3.2.1 Round Island restoration 

Round Island was identified by the MDMR (USACE, 2002 and USACE, 2003) as a possible placement site 

(Figure 4-2 insert). In the 1850’s the original island was approximately 150 acres. The shoreline has been 

eroded and only about 34 – 40 acres still exist. The project’s goal is to restore the island to its 1850’s 

configuration; therefore, the project is considered a “restoration,” not “creation” project. The portion of the 

restoration that is currently funded will require approximately 20,000 cy of material. This site is located 

approximately 6 miles from the Project site (MNI, 2005). Construction at this site cannot proceed until adjacent 

fish habitat is clarified. 

4.3.2.2 Greenwood Island restoration 

Greenwood Island covers approximately 190 acres and is located on the west side of the mouth of Bayou 

Casotte. The diked disposal area contains about 101 acres with dike elevations in 1985 of 18 to 19 feet. The 

Greenwood Island disposal area is about 0.7 miles from the Project site and has generally accommodated 

maintenance dredged material from the mouth of the Bayou Casotte Harbor to the inland terminus of the 

channel. Greenwood Island was originally an island and the deposition of dredged material is responsible for 

its current attachment to the mainland. The disposal area at Greenwood Island has been determined to be 

unsuitable for continued use due to site contamination. The entire island, including the existing disposal site, is 

owned by the Jackson County Port Authority. The Mississippi Coastal Program includes Greenwood Island in 

a list of waterfront erosion and accretion areas, and states that the Greenwood Island area of Bayou Casotte 

bears the brunt of waves generated over a long fetch from the southeast through Petit Bois Pass. The Coastal 

Wetlands Use Plan designates the area as S-4 (Special Use – dredged material disposal and disposal island). 

Hurricane George hit Greenwood Island in 1998 and further eroded the island. In order to restore the island 

dredged material consisting of rubble and fill material would be used to stop shoreline erosion. 

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The expansion of Greenwood Island consists of tying into the existing dikes at Greenwood Island and creating 

a confined disposal area that extends into the Mississippi Sound. The area is bordered on the east by the 

Bayou Casotte Channel and on the west by a recreation channel that leads to Pascagoula’s yacht club. Port 

Authority plans include a barge fleeting area and terminal development. The area, approximately 65 acres, 

includes a proposed rail spur from the airport site to the east side of Greenwood Island. To provide adequate 

area for disposal a long peninsula-shaped disposal area would have to be constructed. 

Currently the disposal site consists of open water and marsh. The site is inactive and a permit status has not 

been coordinated. A levee and weir would have to be constructed before any dredged material could be 

disposed. (MNI, 2005) 

4.3.2.3 South wetland restoration 

The South Wetland Restoration alternative is a new site at the conceptual stage of development and was not 

included in the previous beneficial use studies by USACE and MDMR (USACE, 2002 and USACE, 2003). 

This site is located approximately one mile south of the Project site along the south facing coastline (Figure 

4-2). The objective would be to restore the shoreline to a historic location, either 1850 or 1950. Figure 4-2 

shows the current and historic shorelines. Restoration will require construction of a containment dike 

approximately 8,800 feet long to establish a shoreline and protect the marsh to be created. If the 1850 

shoreline is restored, the total area of marsh would be over 100 acres. The volume of dredged material that 

could be placed would be between 0.5 mcy and 1 mcy. This site will require extensive coordination with 

USACE, MDMR and the property owners before further analyses is done. 

4.4 Maintenance dredging 

The ODMDS is also considered to be the best alternative for placement of the maintenance dredged material 

from the proposed LNG terminal. The permit for the new work dredging with placement at ODMDS also covers 

any maintenance dredging within the first three years after construction. Maintenance material removed after 

the first three years would have to be tested and characterized as part of the permitting process. However, it 

should be noted that Bayou Casotte Energy may reduce environmental impacts by coordinating their 

maintenance dredging with USACE maintenance dredging of the Bayou Casotte channel. This would in effect 

necessitate using the same placement area as USACE. Use of one or more beneficial use sites will also be 

considered based on timing and availability. At this time the same three sites recommended for the initial 

Project and any new sites will be evaluated for future maintenance material placement. 

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5-1 July 2006

5.0 Dredging operations

This section describes the general requirements needed to implement the recommended dredging and 

placement plan including equipment, operational logistics and timing. Prior to construction, conditions deemed 

to be necessary to minimize impacts from dredging and placement operations will be included in the plans and 

specifications for the Project. Anticipated requirements by resource agencies are outlined in the following 

sections. 

5.1 Dredging equipment 

Based on the recommended plan for initial work and future maintenance of the Project, two types of dredges 

will likely be used: mechanical and hydraulic. 

5.1.1 Mechanical dredges 

Mechanical dredges are typically used where the area to be dredged has restricted access or operating space 

and/or when the placement site is a significant distance from the dredging site. Mechanical dredging is often 

required when the soil is very hard or compacted. Typically a clamshell (Figure 5-1)), backhoe (excavator) 

(Figure 5-2), or ladder dredge is used. Each type of mechanical dredge uses some sort of bucket to excavate 

the material. Backhoe and ladder dredges are often required to excavate dense material due to the positive 

digging force they can exert. Because the material to be dredged from the slip does not contain hard material 

it is unlikely that the backhoe or ladder type dredge will be used. Clamshell buckets are also capable of 

removing large debris that hydraulic dredges can not remove. Generally the dredged material is loaded onto a 

separate barge or scow which is used to transport material to the placement site. Closed hull barges and 

scows need to be discharged by either mechanical or hydraulic means. Open-hull barges including split-hull 

scows, have the ability to release the sediment from the bottom of the vessel, allowing for a faster turn-around 

time in offshore placement sites. (MNI, 2005) 

Figure 5-1 Typical clamshell dredge with disposal scow (MNI, 2005) 

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Figure 5-2 Typical backhoe (excavator) dredged (MNI, 2005)

5.1.2 Hydraulic dredges 

Hydraulic dredging is used to remove softer materials using a pump to discharge a slurry mix. Hydraulic 

dredges can excavate a variety of materials including stiff clays and dense sands. Several variants of 

hydraulic dredges exist including plain suction, cutterhead, dustpan, and water injection dredges. The 

cutterhead dredge (Figure 5-3) uses rotating cutting apparatus around the intake of a suction pipe to allow 

suction of harder materials. Hydraulic dredging is generally much faster than mechanical dredging, so it is 

typically preferred when dredge material properties are suitable. The dredged material is pumped through a 

pipeline which can be placed on land, floating, submerged on the seabed, or even buried. The dredged 

material slurry is typically pumped directly to a placement area, but can be pumped into scows which are then 

transported to the placement site and emptied similar to mechanical dredging methods. In a typical application 

dredged material is pumped up to 25,000 ft; in-line booster pumps can be added to increase the pumping 

distance to 50,000 ft or greater. However, adding booster pumps increases pumping cost and typically 

decreases productivity. Booster pumps can be located on land, on jack-up type rigs, or on moored barges. 

Hydraulic dredges are generally rated based on the size of the discharge pipe, ranging from 6 in. to 30 in. 

Smaller dredges can be used for smaller, shallower dredge cuts and some small dredges are even trailer-able. 

Larger dredges have higher production rates and are typically more cost effective for large projects and can 

pump dredged material longer distances without booster pumps. A typical 30” dredge is capable of placing up 

to 1,800 to 2,000 cy per hour of material (28,000 to 30,000 cy per day). 

Figure 5-3 Typical cutterhead hydraulic dredge 

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5-3 July 2006

5.2 Initial Project dredging 

Dredging of the slip will be conducted using mechanical dredging equipment, such as clamshell or dragline 

dredges mounted on barges. Use of mechanical dredging methods is required for material placed at ODMDS. 

Oversight of all operations will be provided to assure that contract plans and specifications, including permit 

conditions, are followed. 

5.2.1 Slip dredging sequence 

The operation will begin with installation of sheet pile along the shoreline behind Refinery Berth 7 to protect the 

shoreline and the berth structures. Prior to dredging, the contractor will mobilize the necessary equipment to 

perform dredging and placement operations. In addition to a barge mounted mechanical dredge, equipment 

would typically include several barges (scows), a crew boat, a tug for transporting scows to the placement site, 

survey boat and equipment and other vessels or barges needed to support the operation. Detailed pre-dredge 

bathymetric surveys will be completed and approved. Dredging will begin at the southwest corner of the new 

slip, at the edge of the existing shipping channel, and continue counterclockwise around the slip. As dredging 

progresses around the slip, it will be immediately followed by installation of stone riprap as scour protection for 

the side slopes. Relocation of Refinery Berth 7 will be performed in such a way as to minimize the out-ofservice time. The pilings for the new berths will be installed in the newly dredged slip and the new Refinery 

Berth #7 will be completed and commissioned. Then the old Refinery Berth #7 will be removed, the sheet pile 

wall will be removed and the remaining material in the mouth of the slip will be dredged. The contractor will 

perform periodic progress surveys to assure that that required depths are being met without excessive 

overdredging.

5.2.2 Timing 

The timing of the dredging operations will depend on the capacity of the equipment that will be used, including 

the dredge size, bucket capacity and scow size, as well as other factors including permit conditions and 

potential seasonal windows that may affect the cycle time at the dredge and transit to ODMDS. It is 

anticipated that only one dredge will be mobilized for the Project. Because the material to be dredged does 

not contain any hard material the production rate should be consistently high. The dredge is not self propelled 

and requires assistance each time it has to move to a new location within the slip. Once set up it can use its 

spud system to make minor moves forward and backward. Once set up at a location, the depth of material to 

be dredged is significant (up to 46 feet) and will likely result in full or almost full buckets during most dredging 

cycles. Dredging is typically done full time, 24 hours per day, 7 days per week. Breaks in this cycle may 

occur due to weather, equipment maintenance, dredge moves within the slip and unforeseen reasons. 

Resource agencies consulted during the preparation of the DEIS have not required any seasonal constraints 

on dredging or placement operations at this time. 

Material removed via the mechanical dredge will be placed on scows for transport and placement at the 

ODMDS or beneficial use sites. Scow sizes typically range from 1,000 cy to over 7,000 cy. Material that will be 

placed at the beneficial use sites may need to be transported in smaller scows that can navigate shallow 

waters. It is anticipated that the dredging contractor will have at least three scows on site. This allows for one 

scow to be loaded while one is in transit to the placement site and one empty scow standing by. Assuming 

that the average 3,000 cy scow will be used, it is estimated that approximately 10 scow loads will be towed to 

the ODMDS daily using existing shipping channels. If larger scows are used, fewer trips to the ODMDS would 

be required. Scows will be inspected regularly to assure that they are seaworthy, that their bottom release 

mechanisms operate properly and the bottom doors seal properly. 

It is estimated that about 4 to 6 months would be needed to dredge and place the full 3.5 mcy at the ODMDS. 

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5.2.3 Placement 

The placement location(s) at the ODMDS will be specified by the USACE. To assure accurate placement, 

inspectors and/or an automated monitoring system will be on-board for each scow trip to record the time and 

exact location of the placement event. As indicated in the previous section, placement events at ODMDS will 

be continuous over a 4 – 6 month period at an average rate of between 5 and 10 events per day. During 

adverse weather and/or sea conditions, placement operations may be reduced or suspended until safe 

conditions exist to proceed. 

Use of dredged material at beneficial use sites is subject to further study to determine the type of material 

needed and the timing. The Round Island and Greenwood Island Restoration projects have undergone 

feasibility studies but will need engineering and design and construction of containment structures before 

placement of dredged material can take place. The Round Island project is not likely to fit the timing for the 

initial Project. The Greenwood Island Shoreline Erosion Abatement project is considered a beneficial add-on 

to the overall solution by others and will require close coordination with all those involved. The South Wetlands 

Restoration project has been studied only to determine potential capacity. The feasibility of creating the South 

Wetlands has to be evaluated further before detailed engineering and design is initiated and may not be 

available for the initial Project placement. As described elsewhere, the beneficial use sites may change before 

the Project is initiated. The Project will maintain close coordination with USACE and MDMR, who evaluate 

and permit these sites, to assure the best use of Project materials. Because mechanical dredging is required 

for placement at ODMDS, this method would be used to dredge material for placement at the beneficial use 

sites. Small scows may be used to place material at these sites if there is adequate access and sufficient 

depth. It is more likely that scows will be used to transport the material to a location near the placement site 

where hydraulic pumping may then be used to place the material where needed if practical. 

5.2.4 Mitigation measures 

There are no known measures required for mitigating the impacts from dredging operations. Model studies 

were performed for both mechanical and hydraulic dredging methods. The predicted total suspended solids 

resuspended from the dredging operations did not result in water column TSS concentrations significantly 

different from those historically observed in Bayou Casotte (see DEIS, Section 4.3.2.2). 

5.2.5 Environmental Protection 

The contractor will be required to comply with the terms, and conditions of the permits for the dredging and 

dredged material placement operations of the project. The contractor will be required to submit plans, for 

approval, to outline the measures they will take to ensure permit conditions are not exceeded. Plans that are 

part of dredging or dredged material management may include but are not limited to: trash and debris removal; 

spill prevention and response; fish and wildlife encounters; turbidity monitoring to prevent exceedances; and 

other potential extraordinary factors. Contingency plans to ensure compliance and address permit conditions 

will be required and followed. Additionally, the Project will employ environmental Inspectors to provide further 

oversight to ensure operational compliance with all conditions. 

5.3 Maintenance dredging 

Operations required for maintenance of the slip would be governed by the placement option selected. As 

described in Sect. 4.2, the primary option is continued use of the ODMDS for maintenance material. Other 

placement options may be available in the future and would require review and approval prior to permitting and 

implementation. It is possible that some beneficial use options will no longer be available but that others may 

become available prior to future maintenance cycles. As described in Sect. 4.4, the quantity and frequency of 

maintenance dredging will be based on surveys. If maintenance dredged material is placed at the ODMDS it is 

expected that mechanical methods will be used. Use of hydraulic dredging methods would be feasible for use 

on other placement options that are in closer geographic proximity to the Project. 

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6-1 July 2006

6.0 References 

ENSR, 2006a, ENSR Corporation, Draft Dredged Material Management Plan, Casotte Landing Natural Gas 

Import Terminal Project, January 2006 

ENSR, 2006b, ENSR Corporation, Casotte Landing Slip Sediment Evaluation Report, Casotte Landing Natural 

Gas Import Terminal Project, June 2006 

ENSR, 2005a, ENSR Corporation, Casotte Landing Natural Gas Import Terminal Project, Environmental 

Report and Resource Reports, Submitted to the Federal Energy Regulatory Commission, September 2005. 

ENSR, 2005b, ENSR Corporation, Field Sampling Plan and Quality Assurance Project Plan Supporting 

Casotte Landing Slip Dredged Material CWA/MPRSA Suitability testing, November 2005. 

FERC, 2006, Federal Energy Regulatory Commission, Office of Energy Projects, Draft Environmental Impact 

Statement, Casotte Landing Natural Gas Import Terminal Project, Bayou Casotte Energy LLC, May 2006. 

Goodwin and Associates, 2005. Phase I Cultural Resources Survey and Archeological Inventory of the 

Proposed Casotte Landing Natural Gas Import Terminal Project (Casotte Landing), Jackson County, 

Mississippi. Draft Report May 2005. 

MNI, 2005. Moffatt & Nichol International, Dredged Material Management Plan, Final Draft, November 2005. 

Sullivan, Charles L., 1985. The Mississippi Gulf Coast: Portrait of a People. Windsor Publications, Northridge, 

California. 

URS Corporation, 2005a. Pascagoula LNG Environmental Site Assessment Revised Draft Report – Former 

Corning Area. February 2005. 

URS Corporation, 2005b. Reconnaissance Geotechnical Investigation Report – Phase I. Casotte Landing 

LNG Terminal, Pascagoula, MS. Draft Report. 

USACE, 2000, U.S. Army Corps of Engineers, Mobile District, Dredged Material Management Plan for Bayou 

Casotte Inner Harbor, Pascagoula Harbor, Mississippi, June 1998, Revised January 2000. 

USACE, 2002, U.S. Army Corps of Engineers, Mobile District, Long-term Comprehensive Master Plan for 

Beneficial Uses of Dredged Material Along Coastal Mississippi, September 2002. 

USACE, 2003, U.S. Army Corps of Engineers, Mobile District, Project Management Plan, Implementation of 

Comprehensive Master Plan for Beneficial Uses of Dredged Material Along Coastal Mississippi, March 2003. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX F 

ESSENTIAL FISH HABITAT ASSESSMENT 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

1 September 2005 

ESSENTIAL FISH HABIT ASSESSMENT 

Bayou Casotte Energy LLC

Casotte Landing Natural Gas Import 

Terminal Project 

September 2005 

Prepared for: 

Bayou Casotte Energy LLC 

1500 Louisiana Street 

Houston, Texas 77002 

Prepared by: 

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Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

2 September 2005 

TABLE OF CONTENTS

1.0 INTRODUCTION ....................................................................................................................3

2.0 PROJECT DESCRIPTION......................................................................................................5

2.1 Terminal.........................................................................................................................5

2.2 Marine Slip.....................................................................................................................5

2.3 Pipeline Interconnections ..............................................................................................5

3.0 ENVIRONMENTAL DESCRIPTION .......................................................................................6

3.1 Terminal Site .................................................................................................................6

3.2 Natural Gas Pipeline Interconnections ..........................................................................6

4.0 ESSENTIAL FISH HABITAT...................................................................................................8

5.0 MANAGED FISH SPECIES ..................................................................................................11

5.1 Ecological Notes on the EFH Fisheries and Species ..................................................11

5.1.1 Species Common to Bayou Casotte...........................................................11

5.1.2 Additional Species Potentially Present in Bayou Casotte...........................15

5.1.3 Marine Benthic Community ........................................................................18

5.1.4 Summary of Seasonal Abundance.............................................................19

6.0 ASSESSMENT OF IMPACTS ..............................................................................................21

6.1 Impacts to the Freshwater Component of the EFH .....................................................21

6.2 Impacts to the Estuarine Component of the EFH ........................................................21

6.2.1 Primary Dredging Impact............................................................................21

6.2.2 Turbidity Impacts ........................................................................................22

6.2.3 Submerged Aquatic Vegetation and Shellfish Beds...................................24

6.2.4 Potential for Offshore Spills........................................................................24

6.2.5 Summary of EFH Impacts ..........................................................................24

7.0 PROPOSED MITIGATIVE MEASURES ...............................................................................26

8.0 CONCLUSIONS....................................................................................................................28

9.0 REFERENCES CITED..........................................................................................................29

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Appendix 3–A Casotte Landing Natural Gas 

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3 September 2005 

1.0 INTRODUCTION 

Bayou Casotte Energy LLC (Bayou Casotte Energy), a subsidiary of Chevron U.S.A., Inc. 

(CUSA), proposes to build and operate an onshore liquefied natural gas (LNG) import terminal 

and associated facilities (Terminal) south of the existing CUSA Pascagoula Refinery 

(Pascagoula Refinery) on Bayou Casotte, just east of Pascagoula, Mississippi (Figure 1-1, see 

Resource Report 1) in Jackson County. The proposed Casotte Landing Natural Gas Import 

Terminal Project (Casotte Landing, Project, or Terminal) will include a double-berth slip for 

accommodation of an LNG carrier (LNGC); facilities to receive and store LNG offloaded from 

LNGCs; equipment to regasify the LNG; and pipelines to transport natural gas to up to five 

interconnections with the existing United States (U.S.) natural gas transmission system grid on 

and/or near the Terminal site. The Project also will involve the relocation of Pascagoula 

Refinery berths 6 and 7. The Project is designed to convert LNG to natural gas at a nominal 

rate of 1.3 billion standard cubic feet per day (BSCFD). The Terminal location was selected so 

LNG could be regasified using waste heat from the Pascagoula Refinery and to minimize 

environmental impacts. In addition, the Project will be located in an existing industrial area, 

minimizing effects on the local population and environment. The Project site formerly contained 

a refractory brick manufacturing plant that was remediated, closed, and issued “No Further 

Action” status by EPA prior to purchase by CUSA with only remnant foundations remaining. 

This Essential Fish Habitat (EFH) Assessment has been prepared as required by the 

Magnuson-Stevens Fishery Conservation and Management Act of 1976, as amended through 

the Sustainable Fisheries Act (SFA) of 1996 (Magnuson-Stevens Act, Public Law 104-267). 

The Magnuson-Stevens Act was established to identify, conserve, and enhance EFH for those 

species regulated under a federal fisheries management plan (FMP). The objectives of this 

EFH Assessment are to describe how the actions proposed by the Project may affect EFH 

designated by the National Marine Fisheries Service (NMFS) and Gulf of Mexico Fisheries 

Management Council (GMFMC). According to the GMFMC, EFH within the Gulf of Mexico 

includes all estuarine and marine waters and substrates from the shoreline to the seaward limit 

of the Exclusive Economic Zone (EEZ). The area of influence of the Project will be restricted to 

the area of Bayou Casotte that is outlined in Figure 1-1. 

The 1996 amendments to the Magnuson-Stevens Act set forth a mandate for NMFS, regional 

Fishery Management Councils (FMC), and other federal agencies to identify and protect EFH of 

economically important marine and estuarine fisheries. 

A provision of the Magnuson-Stevens Act requires that FMCs identify and protect EFH for every 

species managed by a Fishery Management Plan (FMP) (U.S.C. 1853(a)(7)). There are FMPs 

in the Gulf of Mexico region for shrimp, red drum, reef fishes, coastal migratory pelagics, stone 

crabs, spiny lobsters, coral and coral reefs, and highly migratory species (e.g., billfish, 

swordfish, tuna, and sharks). 

EFH is defined as "those waters and substrate necessary to fish for spawning, breeding, 

feeding, or growth to maturity" (16 USC 1802(10)). NMFS recommends consolidated EFH 

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4 September 2005 

consultations with interagency coordination procedures required by other statutes, such as the 

National Environmental Protection Act (NEPA) and Endangered Species Act (ESA), 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 environmental impact statement 

[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, NMFS will 

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 NMFS within 30 days of receiving 

NMFS' 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. 

This EFH Assessment includes a description of the proposed action, an analysis of the direct 

and cumulative effects on EFH for the managed fish species and their major food sources, 

potential impacts created by the proposed action, and proposed mitigation measures selected to 

minimize expected Project effects if applicable. 

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Appendix 3–A Casotte Landing Natural Gas 

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2.0 PROJECT DESCRIPTION 

Casotte Landing will be located in Mississippi on the east shore of Bayou Casotte, immediately 

north of Mississippi Sound in the eastern, central potion of the Gulf of Mexico (Figure 1-1). The 

Terminal location will be at Longitude 88° 30' 17.28" West, Latitude 30° 19' 55.21" North. 

An important consideration in locating the Project adjacent to the existing Pascagoula Refinery 

is access to the Pascagoula Refinery’s waste heat. This heat, as warm effluent water, will be 

captured and used to provide the heat transfer for the re-gasification process, allowing the 

Terminal to operate using a “closed-loop” system. This “closed-loop” regasification process 

eliminates impingement and entrainment impacts to ichthyoplankton and invertebrate species 

that would be associated with “open-loop” intake of cooling water from the surrounding 

environment. 

2.1 Terminal 

Bayou Casotte Energy is proposing to construct Casotte Landing to be an LNG receiving, 

storage, and regasification facility. The Project will include three full-containment LNG storage 

tanks, six vaporizers, a marine terminal, and a system of natural gas pipeline interconnections. 

2.2 Marine Slip 

Construction of the marine slip will require the excavation of approximately 1.0 million cubic 

yards (mcy) of dry material (with standard earthmoving equipment) and another 3.5 mcy of wet 

material (with mechanical dredging equipment such as clamshells or draglines) from the slip 

area. Clearing the approach channel for the berthing facility will require approximately 338,000 

cubic yards (included in the totals above) of dredging in Bayou Casotte. Construction of the 

Marine Slip will begin with the protection of the shoreline and existing crude berth with sheet pile 

or equivalent. Sediment identified as containing detectable chemical constituents will be 

segregated and removed during site preparation to prevent the potential release of these 

chemicals into the estuarine environment. The slip will be excavated to –46 feet Mean Lower 

Low Water (MLLW) (42 feet nominal depth, 2 feet overdredging, 2 feet advance maintenance) 

using conventional grading equipment until the water table is reached. Below the water table, 

dredging will be conducted with mechanical dredging equipment. Care will be taken to conduct 

the marine sediment dredging at a time when it will have least impacts to essential fish habitat 

as well as threatened and endangered species. 

2.3 Pipeline Interconnections 

Pipeline interconnection construction is expected to require a 110-foot-wide temporary 

construction corridor to adequately and safely install the proposed 36-inch pipeline 

interconnection and an 85-foot-wide construction corridor for each of the smaller-diameter 

pipeline interconnections. Subsequent to construction, a 50-foot-wide permanent right-of-way 

will be maintained to allow for observation and maintenance of the interconnections. The 

pipeline with proposed Terminal location is shown in Figure 2-1. 

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Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

6 September 2005 

3.0 ENVIRONMENTAL DESCRIPTION 

The Gulf of Mexico supports extremely valuable commercial and recreational fisheries in state 

and federal waters. The Pascagoula and Pearl Rivers, Bayou Casotte, and Biloxi Bay are the 

primary sources of nutrients entering Mississippi Sound. High levels of phosphorus and 

nitrogen are found in the Bayou Casotte area where fertilizer manufacturing plants are located 

(GMFMC, 2004). Waters adjacent to industrial areas are subject to effluent discharge and 

associated Benthic Oxygen Demand (BOD) loadings and, thus, exhibit greater variability in 

nutrient levels (GMFMC, 2004). 

Bayou Casotte is designated as a Fish and Wildlife waterbody according to the state’s water 

quality standards. It is listed as an Impaired Water Body under Mississippi’s 2002 and 2004 

(Draft) listing of such waters under Section 303(d) of the Federal Clean Water Act (CWA) based 

on the level of total toxics and un-ionized ammonia. It is anthropogenically disturbed, which was 

considered during the site alternatives review and selection. 

A relatively high number of recreational fishing boats use Bayou Casotte for docking and 

launching operations, but generally take their charters outside of Bayou Casotte. Private 

individuals use Bayou Casotte for recreational fishing, but no commercial fisheries are 

supported within the waters of Bayou Casotte. 

Some shellfish, mainly crabs, are harvested from Bayou Casotte during the appropriate open 

seasons. Bayou Casotte is a nursery area for brown shrimp, but shrimp are not commercially 

harvested within this bayou. The nearest oyster fishery is located in Point-aux-Chenes Bay, 

approximately 0.5 mile southeast of the Project site. The next nearest is in Bangs Lake, 

approximately 1.7 miles northeast of the Project Site. None of these shellfish waterbodies or 

activities is expected to be affected by construction or operation of the Project. There is no 

seagrass located within the Project location [U.S. Geological Survey (USGS) – National 

Wetlands Research Center (NWRC), 2003]. 

EFH potentially impacted by the Project are identified in Table 3-1. 

3.1 Terminal Site 

Waterbodies within the final footprint of the Terminal consist of roadside ditches, artificial canals, 

and stormwater retention ponds, which will be rerouted, replaced, or removed as necessary. 

Drainage patterns downgradient of the site will be maintained in their existing condition. 

Wetlands within the Terminal site will experience temporary construction impacts in laydown 

areas and extra workspaces as well as permanent impacts in the footprint of the Marine Slip 

and Facility. These temporary and permanent impacts to the estuarine environment are 

provided in Table 3.1-1. 

3.2 Natural Gas Pipeline Interconnections 

The waterbodies traversed by the pipeline interconnection routes are shallow, artificial drainage 

ditches and canals and retention ponds, with a maximum depth of less than 10 feet. Many of 

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7 September 2005 

them are dry except after rainfall. Substrates are generally unvegetated or sparsely vegetated 

dredge spoil or dolomite fill from the previous use as a refractory brick manufacturing plant. 

Waterbodies in the pipeline interconnection construction corridor will be crossed using 

techniques appropriate to their environmental sensitivity. The pipeline interconnection route will 

cross freshwater and estuarine wetlands, artificial canals, and roadside ditches. 

TABLE 3-1 

POTENTIAL EFH AFFECTED BY CONSTRUCTION AND OPERATION OF THE PROJECT 

Facility 

Begin 

MP End MP 

Approximate 

Crossing Length 

(feet) 

Wetland 

Type 

Construction 

Requirements 

(acres) 

0.0 0.0 N/A PEM 26.6 

0.0 0.0 N/A PSS 12.1 

0.0 0.0 N/A PFO 0.5 

0.0 0.0 N/A EEM 20.5 

Natural Gas Import 

Terminal 

0.0 0.0 N/A ESS 79.4 

36-inch Gulfstream 

Pipeline Interconnection 

0.5 1.5 5,280 EEM 13.3* 

12-inch Gulf South 

Pipeline Interconnection 

0.6 <0.7 210 EEM 0.4* 

16-inch Destin Pipeline 

Interconnection 

0.6 <0.7 210 EEM 0.4* 

16-inch Chandeleur 

Pipeline Interconnection 

0.6 <0.7 320 EEM 0.6* 

12-inch Chandeleur 

Pipeline Interconnection 

0.6 <0.7 420 EEM 0.8* 

12-inch NGL Pipeline 

Interconnection 

3.7 4.0 1,580 TBD 3.5* 

Totals 8,020 — 158.1 

*Pipelines are co-located. Each entry represents impacts unique to that pipeline. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

8 September 2005 

4.0 ESSENTIAL FISH HABITAT 

EFH potentially affected by the Project is identified and described for various life stages of 19 

managed fish and shellfish species. All federally managed species are listed in Table 4-1, 

including the NMFS-designated Billfish and Highly Migratory Species (NMFS, 2002). Most of 

these species do not have EFH within the boundaries of the Project (GMFMC, 2004) and, 

therefore, will not be impacted by the Project. Although more than 500 species of fish have 

been reported in the federal waters of the Gulf of Mexico, there are only six species that are 

expected to be commonly found in the Project area. These species are brown shrimp, pink 

shrimp, white shrimp, Spanish mackerel, red drum, and gulf stone crab (GMFMC 2004; NMFS 

2002). Species accounts of these six species as well as the other 14 potentially present in 

Bayou Casotte (Table 4-2) are presented below. NMFS’ Estuarine Living Marine Resources 

(ELMR) database provides further information regarding species abundances within the entire 

Mississippi Sound. Results from a database query for Mississippi Sound are provided within 

Appendix 3–A–A of this EFH Assessment Report. 

EFH is separated into freshwater, marine, and estuarine components. There are no natural 

freshwater waterbodies associated with the Project; therefore, the freshwater component of 

EFH will not be affected. The marine component is defined as “all marine waters and 

substrates (mud, sand, shell, rock, hard bottom, and associated biological communities) from 

the shoreline to the seaward limit of the Exclusive Economic Zone” (GMFMC, 2004). The 

estuarine component is defined as “all estuarine waters and substrates (mud, sand, shell, rock 

and associated biological communities), including the sub-tidal vegetation (grasses and algae) 

and adjacent inter-tidal vegetation (marshes and mangroves).” The Project is located adjacent 

to Bayou Casotte and near Mississippi Sound, which are estuarine systems. Therefore, coastal 

estuarine fisheries and marine fisheries with estuarine life stages are considered within this 

analysis. Estuarine fishes include species that inhabit or are commonly associated with 

seagrass beds, oyster reefs, and unvegetated soft bottom habitats. Anadromous and 

catadromous species are not federally managed. Additional details regarding effects of the 

Project to anandromous, catadromous and/or threatened–and-endangered, state–managed, or 

non-federally managed species are provided in Resource Report 3 of the Environmental Report 

(ER). It is important to note that the proposed Project site is outside the area designated as 

Critical Habitat for Gulf Sturgeon (Acipenser oxyrinchus desotoi). No impact to Gulf Sturgeon 

individuals or its Critical habitat is expected as a result of the construction and/or operation of 

this proposed project. 

The Grand Bay National Estuarine Research Reserve (NERR), the only Habitat Area of 

Particular Concern (HAPC) located in Mississippi, lies to the east of the Project, approximately 

7,000 feet from the Terminal site. The proposed Gulfstream pipeline interconnection will 

approach the onshore boundary of the NERR but the short-term disturbance associated with 

pipeline installation (in an existing right-of-way) is unlikely to have significant impacts on the 

HAPC. Dredging/excavation of the slip has the potential to generate turbidity, but results from 

sediment turbidity modeling show that turbidity increases created by this Project will be localized 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

9 September 2005 

and temporary and will not impact the Grand Bay NERR. Please refer to Resource Report 2 of 

this ER for turbidity modeling information. 

TABLE 4-1. FISHERY MANAGEMENT PLANS AND MANAGED SPECIES FOR THE GULF 

OF MEXICO 

GULF OF MEXICO FISHERY MANAGEMENT COUNCIL 

Shrimp Fishery Management Plan 

brown shrimp - Farfantepenaeus aztecus 

pink shrimp - F. duorarum 

royal red shrimp - Pleoticus robustus 

white shrimp - Litopenaeus setiferus 

Red Drum Fishery Management Plan 

red drum - Sciaenops ocellatus 

Reef Fish Fishery Management Plan 

black grouper- Mycteroperca bonaci 

gag grouper - M. microlepis 

gray snapper - Lutjanus griseus 

gray triggerfish - Balistes capriscus 

greater amberjack - Seriola dumerili 

lane snapper - L. synagris 

lesser amberjack - S. fasciata 

red grouper - Epinephelus morio 

red snapper - L. campechanus 

scamp grouper - M. phenax 

tilefish - Lopholatilus chamaeleonticeps 

yellowtail snapper - Ocyurus chrysurus 

vermilion snapper - Rhomboplites aurorubens 

Stone Crab Fishery Management Plan 

stone crab - Menippe spp.

Spiny Lobster Fishery Management Plan 

spiny lobster - Panulirus argus 

Coral and Coral Reef Fishery Management Plan 

varied coral species and coral reef

communities comprised of several

hundred species

Coastal Migratory Pelagic Fishery Mmgt. Plan

bluefish - Pomatomus saltatrix 

dolphin - Coryphaena hippurus 

cobia - Rachycentron canadum 

king mackerel - Scomberomorus cavalla 

Spanish mackerel - S. maculates 

little tunny - Euthynnus alleteratus 

NATIONAL MARINE FISHERIES SERVICE 

Billfish and Highly Migratory Species 

Billfish 

blue marlin - Makaira nigricans 

longbill spearfish - Tetrapturus pfluegeri 

white marlin - T. albidus 

sailfish - Istiophorus platypterus 

Swordfish 

swordfish - Xiphias gladius 

Tuna 

albacore - Thunnus alalunga 

Atlantic bigeye - T. obesus 

Atlantic yellowfin - T. albacares 

skipjack - Katsuwonus pelamis 

western Atlantic bluefin - T. thynnus 

Sharks 

Atlantic angel shark - Squatina dumerili 

Atlantic sharpnose shark – Rhizoprionodon 

terraenovae 

basking shark - Cetorhinus maximus 

bigeye sand tiger - Odontaspis noronhai 

bigeye sixgill shark - Hexanchus vitulus 

bigeye thresher shark - Alopias superciliosus 

bignose shark - Carcharhinus altimus 

blacknose shark - C. acronotus 

blacktip shark - C. limbatus 

blue shark - Prionace glauca 

bonnethead - Sphyrna tiburo 

bull shark - C. leucas 

Caribbean reef shark - C. perezi 

Sharks (continued) 

Caribbean sharpnose shark - R. porosus 

common thresher shark - A. vulpinus 

dusky shark - C. obscurus 

finetooth shark - C. isodon 

Galapagos shark - C. galapagensis 

great hammerhead - S. mokarran 

lemon shark - Negaprion brevirostris 

longfin mako shark - Isurus paucus 

narrowtooth shark - C. brachyurus 

night shark - C. signatus 

nurse shark - Ginglymostoma cirratum 

oceanic whitetip shark - C. longimanus 

porbeagle shark - Lamna nasus 

sandbar shark - C. plumbeus 

sand tiger shark - O. taurus 

scalloped hammerhead - S. lewini 

sharpnose sevengill shark – Heptranchias perlo 

shortfin mako shark - I. oxyrinchus 

silky shark - C. falciformis 

sixgill shark - H. griseus 

smalltail shark - C. porosus 

smooth hammerhead - S. zygaena 

spinner shark - C. brevipinna 

Tiger shark - Galeocerdo cuvieri 

whale shark - Rhinocodon typus 

white shark - Carcharodon carcharias 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

10 September 2005 

TABLE 4-2. GULF OF MEXICO FEDERALLY MANAGED FISHERY RESOURCES WITH 

DESIGNATED EFH WITHIN PROJECT AREA 

Fishery Management Unit 

Common Name 

(all life stages present unless otherwise 

noted) Scientific Name 

Shrimp Fishery Brown shrimp Farfantepenaeus aztecus

White shrimp Litopenaeus setiferus

Pink shrimp Farfantepenaeus duorarum

Red Drum Fishery Red drum Sciaenops ocellatus

Reef Fishery Gag grouper Mycteroperca microlepis

Gray snapper 

(juveniles and adults only) 

Lutjanus griseus 

Red snapper 

(juveniles only) 

Lopholatilus chamaeleonticeps

Lane snapper 

(juveniles only) 

Lutjanus synagris

Coastal Migratory Pelagics King mackerel 

(juveniles only) 

Scomberomorus cavalla

Spanish mackerel 

(juveniles and adults only) 

Scomberomorus maculatus

Cobia 

(juveniles and adults) 

Rachycentron canadum

Stone Crab Fishery Stone Crab 

(all stages but rarely found) 

Menippe mercenaria 

Gulf Stone Crab Menippe adina 

NMFS Billfish and Highly Migratory Species 

Scalloped hammerhead shark 

(rarely found, late juvenile/subadult) 

Sphyrna lewini 

Blacktip shark 

(rarely found, late juveniles) 

Carcharhinus limbatus 

Tiger shark 

(rarely found, juveniles only) 

Galeocerdo cuvieri 

Bonnethread shark Sphyrna tiburo 

Atlantic sharpnose shark 

(all stages, but rarely found) 

Rhizoprionodon terraenovae 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

11 September 2005 

5.0 MANAGED FISH SPECIES 

The seasonal and year-round locations of designated EFH for the managed fisheries are 

depicted on the figures available on the NOAA Fisheries' Galveston web page 

(http://galveston.ssp.nmfs.gov/research/fisheryecology/EFH/Relative/estuaries/). Several of 

these images are included within Appendix 3–A–B of this EFH Assessment. The EFH 

determination is based on species-distribution maps, ELMR data, reports within the Generic 

Essential Fish Habitat Amendment for the above-listed FMPs (Table 4-2) for the Gulf of Mexico 

(GMFMC, 2004) and habitat association tables found within Species Profiles produced by the 

USGS (http://www.nwrc.usgs.gov/publications/ specindex.htm). In figures provided by NOAA 

Fisheries Galveston, the EFH of each estuarine species consists of those areas depicted on the 

maps as “common,” “abundant,” and “highly abundant”. In offshore areas, EFH consists of 

those areas depicted as “adult areas,” “spawning areas,” and “nursery areas.” After reviewing 

all of these resources, a determination was made regarding potential impacts to species that 

might be found within the Project area. 

5.1 Ecological Notes on the EFH Fisheries and Species 

A brief summary of ecological information was compiled for each species that may be affected 

by the Project. Especially sensitive areas (followed by the season or months of peak sensitivity) 

such as “spawning area” or “nursery area” are given for species where the description might 

help in mitigating impacts through scheduling of construction activities. Table 5.1-1 summarizes 

the information. These species are addressed in two groups: species common to Bayou 

Casotte and species potentially present (but not common), based on ELMR records and 

consultation with NMFS (NMFS, 2005). 

5.1.1 Species Common to Bayou Casotte 

Brown Shrimp (Farfantepenaeus aztecus) 

Brown shrimp inhabit coastal waters from low tide to a depth of approximately 110 meters (m) 

throughout the Gulf of Mexico, and are most abundant off the coasts of Texas, Louisiana, and 

Mississippi. Non-spawning adults prefer turbid waters to soft sediments (i.e., mud and sand). 

In the spring and fall, adult brown shrimp move to slightly deeper waters (46 to 91 m) to spawn. 

Brown shrimp eggs are demersal. Larval brown shrimp are most abundant offshore, but do 

occur in waters that range from 0 to 82 m deep. Post-larval brown shrimp migrate to shallow 

vegetated habitats in estuaries in the spring. Late post-larval and juvenile brown shrimp are 

most abundant in shallow (less than 1 m) estuarine habitats in the spring and early summer, but 

typically are present through the fall. 

Within the estuarine environment, juvenile brown shrimp prefer marsh edges and areas with 

submerged vegetation, but occur throughout the estuary (vegetated and non-vegetated 

habitats) and in the lower reaches of its tributaries. Juvenile abundance peaks after spawning 

in the spring and by mid-summer most will have moved back offshore. Sub-adults are most 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Appendix 3–A 

Essential Fish Habitat Assessment 

12 

Table 5.1-1. Summary of life stages for federally managed species describing their presence or absence near Ba

Life Stage 

Brown 

Shrimp 

White 

Shrimp 

Pink 

Shrimp 

Red 

Drum 

Gag 

Grouper 

Gray 

Snapper 

Red 

Snapper

Lane 

Snapper

Stone 

Crab 

Gulf 

Stone 

Crab 

King 

Mackerel

Spanish 

Mackerel Co

Eggs - - - - - - - - - - 

Seasonal 

AppearanceEggs 

- - - - - - - - 

Larvae 9 - - 

Seasonal 

AppearanceLarvae 

 common 

Sept.-

Jan. 

Juveniles 9 9 9 9 9 9 9 9 9 9 Seasonal 

AppearanceJuveniles 

H.A. 

May-July 

found 

year 

round 

Abu. 

JuneSept 

found 

year 

round 

common 

year 

round 

common 

year 

round 

present 

JuneOctober 

common 

June-Aug. 

present 

Oct.-Jan. 

present 

July-Oct. 

present 

July-Oct. 

present 

June-Sept 

pre

M

O

Adults 9 9 9 - 9 - - - 9 

Seasonal 

AppearanceAdults 

Abu. 

July-Oct. 

found 

year 

round 

Abu. 

JuneSept 

found 

year 

round 

common 

year 

round 

common 

Feb.-Oct. 

 rarely 

found 

 present 

June-Sept 

pre

M

O

Spawning 

Adults 

- - - - - - - - - - 

Seasonal 

AppearanceSpawning 

Adults 

All 

stages 

rarely 

found. 

All stages, 

except 

brooding 

females, 

found 

year 

round. 

Brooding 

females 

found from 

March – 

October. 

- - 

- = absent, 9 = present, H.A. = Highly Abundant, Abu. = Abundant 

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Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

13 September 2005 

abundant in slightly deeper waters (1 to 18 m) than juveniles and prefer sand, mud, and shell 

substrates to the vegetated bottoms preferred by juveniles. As they develop, sub-adult brown 

shrimp continue to migrate toward deeper waters, eventually leaving the estuarine nurseries in 

mid-summer. 

Adults are abundant in Bayou Casotte, based on GMFMC distribution figures, July though 

October, with common presence in the remaining months of the year. Spawning takes place 

offshore and Bayou Casotte is not considered a spawning area for brown shrimp. Juveniles are 

highly abundant May though July, with abundances decreasing throughout the remainder of the 

year. Bayou Casotte is considered a “major nursery area” for this species. 

White Shrimp (Litopenaeus setiferus) 

Non-spawning adult white shrimp inhabit offshore waters in the winter and move inshore in the 

spring. Spawning generally occurs offshore from spring to late fall (spawning peaks in the 

summer between June and July). Eggs are demersal and share the same distribution as the 

offshore spawning adults. Larval white shrimp hatch within 12 hours of spawning and begin to 

migrate toward estuaries as they develop into post-larvae. Estuarine migration peaks between 

June and September. 

Juvenile white shrimp are most abundant in turbid estuaries of the Gulf of Mexico and, within 

these estuarine nurseries, reach their greatest densities in marsh edge habitats and in areas 

with submerged aquatic vegetation. However, juvenile white shrimp also are common in marsh 

ponds, channels, inner marshes, shallow subtidal areas, and oyster reefs. In non-vegetated 

areas, post-larval and juveniles inhabit mostly muddy substrates with large quantities of detritus. 

Sub-adult white shrimp move from the estuaries to coastal areas in late August and September 

as they migrate offshore for spawning. 

Bayou Casotte area is not considered a spawning ground for white shrimp. Bayou Casotte is a 

year-round habitat for adults and juveniles. They will likely be found at the site in their greatest 

abundance from June through September. 

Pink Shrimp (Farfantepenaeus duorarum) 

Juvenile pink shrimp inhabit most estuaries in the Gulf but are considered to have their greatest 

abundance along the west coast of Florida where they have their major spawning areas. 

Juveniles are commonly found in estuarine areas with seagrass, such as Halodule wrightii and 

Thalassia testudinum. Postlarve, juvenile, and subadults may prefer coarse sand/shell/mud 

mixtures. Typically, adults inhabit offshore marine waters, with the highest concentrations in 

depths of 30 to 144 feet but can be found inshore, as well. 

According to the GMFMC species-distribution maps, pink shrimp juveniles and adults are 

common in Bayou Casotte year round. However, Bayou Casotte is not considered to be a 

spawning ground or “major nursery area” for Pink Shrimp. The juvenile and adult stages are 

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Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

14 September 2005 

never considered to be highly abundant within Bayou Casotte. 

Red Drum (Sciaenops ocellatus) 

In the Gulf of Mexico, red drum occur in a variety of habitats, ranging from depths of about 40 m 

offshore to very shallow estuarine waters. They commonly occur in virtually all of the Gulf of 

Mexico’s estuaries (GMFMC, 2004), where they are found over a variety of substrates including 

sand, mud, and oyster reefs. Red drum can tolerate salinities ranging from freshwater to highly 

saline, but optimum salinities for the various life stages have not been determined. The 

GMFMC considers all estuaries in the Gulf of Mexico to be EFH for red drum. 

Spawning occurs in deeper water near the mouths of bays and inlets, and on the Gulf side of 

the barrier islands (Perret et al., 1980) from September through November. Eggs typically hatch 

in late summer and early fall and larvae are transported into estuaries where the fish mature 

before moving back to the Gulf of Mexico (Pattillo et al., 1997). Larval red drum are most 

abundant in estuaries from mid-August through late November. Estuarine wetlands are 

especially important to larval, juvenile and subadult red drum. 

NOAA Fisheries’ ELMR data indicate that larval red drum are absent February through August 

in Mississippi Sound (Bayou Casotte is adjacent to Mississippi Sound). Juvenile and adult red 

drum are reported as common at all salinities throughout the year within Mississippi Sound. 

Bayou Casotte is not considered a spawning ground or year-round nursery for red drum based 

on GMFMC figures. Adults are rarely found in the Bayou Casotte area from November through 

January, however, adults are common during the remaining months of the year. Larvae will 

most likely be found from September through January and juveniles are common in the Bayou 

Casotte area year round. Adult red drum are fast swimmers and will likely avoid areas of 

construction. It is possible that younger stages of red drum will have the potential for greater 

impact from dredging and construction of the Project. 

Spanish Mackerel (Scomberomorus maculatus) 

Spanish mackerel are pelagic. NOAA Fisheries (2002) states that this species occurs at depths 

50m or less in the Gulf of Mexico from Florida through Texas. Adults usually are found in neritic 

waters and will inhabit estuarine areas, especially the higher salinity areas and during seasonal 

migrations, but are considered rare and infrequent in many Gulf of Mexico estuaries. Spawning 

occurs from May to October, offshore. Larvae are most frequently found offshore over the inner 

continental shelf. Juveniles are found in a variety of habitats including beach surf, estuarine 

habitat, and deeper offshore waters. ELMR data (Appendix 3–A–A) indicates that Spanish 

Mackerel eggs and larvae are not found within Mississippi Sound. Adult Spanish mackerel are 

commonly found in Mississippi Sound from June through August, only. The remaining months, 

this species is either absent or rarely found. Juvenile Spanish Mackerel are commonly found in 

Mississippi Sound from April through November and can tolerate salinities as low as 5 parts per 

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Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

15 September 2005 

trillion (ppt). The likelihood of finding Spanish Mackerel juveniles in Bayou Casotte during this 

time is relatively high based on ELMR data. 

Eggs and larvae of Spanish mackerel are not found in Bayou Casotte. Juvenile and adult 

stages of this species may be found in Bayou Casotte with greatest abundances in the late 

spring and summer months. Adult Spanish Mackerel are highly migratory and mobile and will 

likely avoid areas of disturbance. 

Gulf Stone Crab (Menippe adina) 

Mississippi Sound is considered an “adult area” for the gulf stone crab as well as a nursery 

habitat. Eggs are brooded beneath the female abdomen and their distribution is subtidal to 

shallow shelf across the northern Gulf of Mexico. Larvae are most abundant in the late spring 

and summer throughout Mississippi Sound and are pelagic. As the larvae age, they become 

oriented toward benthic existence. Late juvenile stages are most abundant from late fall 

through spring, and adult stages are found from March through September in shallow subtidal 

and intertidal habitat. Adults can be found on intertidal mud flats, oyster reefs, rock jetties, mud 

bottoms near pilings and structures, and along the edges of channels in the mid-estuarine 

environment 

It is likely that adults, larvae, and juveniles of gulf stone crabs will be present within Bayou 

Casotte year round based on GMFMC (2004). The most sensitive life stage is the gravid 

female, which broods fertilized eggs beneath the abdomen. This stage is present from October 

to March. 

5.1.2 Additional Species Potentially Present in Bayou Casotte 

Gag Grouper (Mycteroperca microlepis) 

Gag grouper adults are indicated on the GMFMC figures to occur within the Project area but not 

abundantly. NOAA Fisheries (2002) indicates that eggs are planktonic and are found offshore, 

mainly off the west Florida coast where spawning occurs. Larvae develop into juveniles within 

40-50 days and move inshore during this time. Early juveniles prefer habitat with submerged 

aquatic vegetation (SAV), oyster beds in coastal lagoons, and estuaries and can be found in the 

Bayou Casotte area from June through October. Late juveniles return to the reefs in the fall to 

mature into adults. Adults prefer hard bottoms, reefs and coral with depths ranging between 10-

100m. 

Because adults prefer hard bottom and coral reef habitat, they will not likely be found within 

Bayou Casotte and the area is not a spawning ground for gag grouper. Juveniles may be found 

in Bayou Casotte and Mississippi Sound, based on life history tables provided by the GMFMC, 

from late spring through early fall. 

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Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

16 September 2005 

Gray Snapper (Lutjanus griseus) 

Spawning adults, eggs, and larvae are not present within Bayou Casotte as these life stages are 

only found offshore. Based on OAA Fisheries’ ELMR data, adults are rarely found within 

Mississippi Sound. The juvenile stage of gray snapper will be the most common life stage that 

may be found within the Project area or Mississippi Sound. Juveniles will be present with 

greatest abundances from June through November. 

Bayou Casotte does not provide EFH for spawning adults, eggs, or larvae of gray snapper. 

Adult gray snapper are reported to be rarely found within Mississippi Sound from NOAA 

Fisheries ELMR data. During summer months, juvenile gray snapper may be commonly found 

in Mississippi Sound estuarine waters with salinity ranging from 15-25 ppt, salinity similar to that 

found in Bayou Casotte. Based on this ELMR data, juvenile gray snapper will potentially be 

found in Bayou Casotte. 

Red Snapper (Lutjanus campechanus) 

Spawning adults, eggs, larvae, and adult stages of red snapper are not found within Bayou 

Casotte. The only life stage that may be found in the vicinity of the Project area is the juvenile 

stage. This stage prefers habitat that is structured with sand and mud. The GMFMC shows 

that the entire Mississippi Sound is considered EFH for the juvenile stage of red snapper. 

Juveniles will likely be found within Mississippi Sound in the late fall and early winter, after 

summer spawning is completed. 

Lane Snapper (Lutjanus synagris) 

Spawning adults, eggs, larvae, and adult stages of lane snapper do not occur in the Bayou 

Casotte area. Only juvenile stages may be found in the sand and mud habitat based on 

information from NMFS (2002). The juvenile stage of lane snapper will be found within 

Mississippi Sound after the larvae mature and migrate to estuarine habitats in the late summer 

and early fall. 

Stone Crab (Menippe mercenaria) 

All life stages of stone crabs are found rarely throughout Mississippi Sound and therefore will 

not likely be found in Bayou Casotte. The greatest abundances of stone crabs (all life stages) 

are found off the southwest coast of Florida (GMFMC, 2004). There is a very low likelihood that 

any life stage of stone crab will be impacted by the Project. 

King Mackerel (Scomberomorus cavalla) 

King mackerel juveniles are the only life stage of this fish that may be found in the vicinity of 

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Essential Fish Habitat Assessment Import Terminal Project 

17 September 2005 

Bayou Casotte based on NMFS (2002) with the greatest abundance from July through October. 

Cobia (Rachycentron canadum) 

Only the juvenile and adult stages of Cobia are found within Mississippi Sound (NMFS, 2002; 

GMFMC, 2004). The spawning adults, eggs, and larvae of this species are located off the 

Florida coast and northward Atlantic locations. This species is highly migratory; adults are only 

found in the Mississippi Sound area in the summer. Mississippi Sound is considered a nursery 

habitat for juvenile Cobia and this life stage can be found in the Project area from April through 

October. 

Spawning adults, eggs, and larvae are not found in Bayou Casotte. Adults and juveniles can be 

found in Bayou Casotte from mid- spring through early fall. Cobia are highly mobile and are 

anticipated to avoid the area disturbed by dredging. 

Scalloped hammerhead shark (Sphyrna lewini) 

This species is circumglobal, residing in coastal warm temperate and tropical seas. Females 

give birth to live pups and it is reported in NMFS (2002) that the juvenile/subadult stage uses 

Mississippi Sound as a nursery area. The young scalloped hammerhead shark can be found 

from shoreline to 50 m depths. It is possible that Bayou Casotte could serve as a nursery 

habitat for scalloped hammerhead shark juveniles and young adults. 

Blacktip shark (Carcharhinus limbatus) and Tiger Shark (Galeocerdo cuvieri) 

NMFS (2002) lists the juvenile stages of blacktip and tiger sharks as the only life stage of these 

species present in Mississippi Sound and they are rarely found in this area. It is highly unlikely 

that the Project will impact any juvenile blacktip or tiger shark. 

Bonnethead shark (Sphyrna tiburo) 

All life stages of the bonnethead shark are found in the northern Gulf of Mexico (NMFS, 2002). 

The juveniles of this species prefer inlets, estuaries, and coastal waters less than 25 m. Adults 

have a distribution from Mobile Bay, Alabama, to South Padre Island, Texas. The juveniles and 

adults are the only stages that will be found in the vicinity of Bayou Casotte. These life stages 

of bonnethead shark are highly mobile and predatory. They will likely avoid areas of 

construction and will not be impacted by the Project adjacent to Bayou Casotte. 

Atlantic sharpnose shark (Rhizoprionodon terraenovae) 

Adults and juveniles of this species are listed in NMFS (2002) as being present in Mississippi 

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Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

18 September 2005 

Sound but are rarely found in this area. Because this species is so rarely found, the Project in 

Bayou Casotte will not have an impact to the status of this species. 

5.1.3 Marine Benthic Community 

Previous sampling efforts over broad areas of the northern Gulf of Mexico shelf as well as other 

marine habitats have demonstrated that sediment type is important in determining benthic 

infaunal communities. Shaw et al. (1982) surveyed infauna in the inner shelf area off 

Mississippi Sound. This comprehensive survey describes distinct infaunal assemblages that 

are associated with mud, muddy sand, or sandy substrata within varied depth zones in shelf 

waters. Barry A. Vittor & Associates, Inc. (1985) reviewed Shaw et al. and other 

Mississippi/Alabama benthic infaunal data, summarizing it in their review entitled “Tuscaloosa 

Trends Regional Data Search and Synthesis Study, Volumes I & II.” In this work they described 

four depth-related benthic habitats for infaunal communities in the northeast Gulf of Mexico 

region. These four habitats are as follows: 

1. shallow beach habitat 

2. inner shelf habitat 

3. intermediate shelf habitat 

4. outer shelf habitat 

Each of these habitats was further divided into sediment type (mud, sandy mud, muddy sand, or 

sand). Infaunal assemblage associations were recognized with each combination of water depth 

and substratum type. Cluster analysis revealed that infaunal taxa were closely tied to sediment 

type and texture. The inner shelf habitat recognized eight distinct infaunal assemblages in the 

area existing from 4 to 20 m depth. Three of these inner shelf assemblages exhibited narrow 

sediment texture preferences, while the other five assemblages showed transitional distributions 

(Byrnes et al., 1999; Vittor & Associates, Inc., 1985). Muddy sand (50% to 90% sand) did not 

support a habitat-specific assemblage on the inner shelf, but instead was inhabited by 

transitional taxa that extended their range into areas characterized by other sediment types 

(Byrnes et al., 1999; Vittor & Associates, Inc., 1985). Those assemblages that exhibited a 

narrow preference for a particular sediment texture were associated with mud, sandy mud, or 

sand (Byrnes et al., 1999; Vittor & Associates, Inc., 1985). The mud (<20% sand) habitat 

assemblage was represented by the hemichordate Balanoglossus cf. aurantiacus, the 

polychaete Paramphinome sp. B, and the mollusks Nassarius acutus and Utriculastra

canaliculata. The sandy mud (20% to 50% sand) habitat assemblage included the ophiuroids 

Hemipholis elongata and Micropholis atra, the bivalve Nuculana concentrica, and the crab 

Pinnixa pearsei (Byrnes et al., 1999; Barry A. Vittor & Associates, Inc., 1985). Bayou Casotte is 

enriched with nitrogen and phosphorous from nearby fertilizer production facilities. The State of 

Mississippi’s 2000 Water Quality Assessment Report indicated low levels of contaminants within 

Bayou Casotte. Vittor & Associates, Inc. (1985) reports that the estuarine sediments in the 

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Mississippi Sound area are characterized as having mostly silt and clay sediments with patchy 

areas of fine to medium sand near shoals and inter-island passes. Bayou Casotte is a 

moderate to low energy depositional environment. The marine sediment from this area has 

been described as marine silts mixed with fine to very fine sands. Therefore, it is likely that the 

infaunal communities within Bayou Casotte are of the mud (<20%) assemblage with some 

ubiquitous taxa, including the bivalve Mulinia lateralis and the polychaetes Armandia maculata, 

Magelona sp. H, Mediomastus, Owenia fusiformis, and Paraprionospio pinnata . These species 

are well adapted to burrowing and foraging in fine sediments. Feeding is one of the behavioral 

aspects most closely related to sedimentary habitat (Rhoads, 1974). Habitats with fine-textured 

sediments and little or no current are characterized by the deposition and accumulation of 

organic material, thereby favoring the occurrence of surface and subsurface deposit feeding 

taxa (Rhoads, 1974). 

Hypoxia is known to occur in the Mississippi Sound region, and may be caused by water column 

organic enrichment and other hydrological factors. Bayou Casotte may experience seasonal 

hypoxia that will affect the diversity and abundance of benthic communities. The major 

invertebrate groups that comprise benthic assemblages exhibit varied levels of tolerance to 

hypoxia. Polychaetes are the most tolerant group, followed by bivalves. Crustaceans and 

echinoderms seem to be the least tolerant of hypoxic conditions (Byrne 1999; Stickle et 

al.,1989). Opportunistic infauna that commonly occur in Mississippi coastal waters, such as the 

polychaetes P. pinnata, Heteromastus filiformis, and Streblospio benedicti, commonly inhabit 

hypoxic areas. The inherent variability of local benthic habitats causes the coastal, inner shelf 

infaunal community to be dynamic, unstable, and to remain in an intermediate level of 

succession state (Rhoads and Germano 1982). These species are opportunistic; they 

reproduce rapidly and re-colonize their habitat rapidly (Rhoads and Germano, 1982). 

5.1.4 Summary of Seasonal Abundance 

The abundance of the six species common to Bayou Casotte was examined to determine 

whether impacts to these species could be minimized by scheduling construction activities for 

periods of minimal abundance. The data presented (NOAA, 2005) are for the entire Mississippi 

Sound, not for Bayou Casotte. Abundance data for Bayou Casotte is not available, but is 

assumed to be similar in pattern to those from Mississippi Sound. 

• Brown shrimp juveniles are highly abundant in May and June. Adults are abundant from 

June through August. Both juveniles and adults are present/common throughout the 

year. Other stages are not present in Bayou Casotte (NOAA, 2005). 

• White shrimp juveniles and adults are common throughout the year, and juveniles are 

abundant from June to November. Larvae are common from May to November and 

abundant from June to October. Eggs and spawning adults are rare or absent from 

Bayou Casotte (NOAA, 2005). 

• Pink shrimp juveniles and adults are present throughout the year. Adults are abundant 

from March to May. Larvae are present only from May to August. Other stages are not 

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present in Bayou Casotte (NOAA, 2005). 

• Red drum adults and juveniles are common throughout the year. Eggs are absent from 

the area. Larvae are abundant from September to January and generally rare the rest of 

the year. Spawning adults are rare or absent from Bayou Casotte (NOAA, 2005). 

• Spanish Mackerel juveniles and adults are present (rare to common) from April to 

October but are never abundant. Other stages are not present in Bayou Casotte 

(NOAA, 2005). 

• Gulf stone crab adults and juveniles are common throughout the year. Spawning adults 

are common from March to October. Eggs are brooded on females and larvae are 

common April through September (NOAA, 2005). 

Preliminary examination of the seasonal patterns of abundance for these species suggests that 

at least one of the six species examined is present at all times of the year. Because the area to 

be dredged is a small section of unvegetated benthic habitat in a frequently dredged industrial 

shipping channel, the proposed dredging is unlikely to have significant long-term effects on the 

EFH regardless of the season during which it is conducted. However, Bayou Casotte Energy 

will work with NMFS to refine the dredging schedule if necessary to minimize dredging impacts 

to the extent practicable. 

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6.0 ASSESSMENT OF IMPACTS 

In this section, potential impacts to managed species and their associated EFH including 

benthic infauna are examined. Identifiable impacts generated by the proposed action for the 

freshwater, estuarine, and marine components of EFH are described. Potential environmental 

consequences that may result from impacts to EFH are reviewed. 

The installation of the Terminal and associated pipeline connection will require site preparation, 

dredging, trenching, directional drilling, pipe fabrication, non-destructive examination, coating of 

completed welds, pipeline lowering, backfill, and safety testing. In addition, shoreline 

construction of the Terminal will require filling and construction and installation of steel pilings. 

Dredging of the mouth of the slip will render the greatest impacts to EFH and the species likely 

found in Bayou Casotte. The depth of water in the proposed marine slip will be 46 feet (42-foot 

control depth plus 2 feet of overdredging and 2 feet of advance maintenance). There will be 

minimal EFH impacts created by pipelay because the proposed pipeline interconnections are 

restricted to artificial waterbodies. 

6.1 Impacts to the Freshwater Component of the EFH 

The freshwater waterbodies associated with the Project site are intermittent drainage ditches, 

artificial canals, and stormwater retention ponds. There are no natural freshwater waterbodies 

on or adjacent to the site. Creation of the marine slip and preparation and fill of the Terminal 

site will involve removal or fill of the waterbodies on the Terminal site. Because these 

waterbodies are low-quality, artificial stormwater conveyances, little or no impact to EFH is 

anticipated. 

The pipeline interconnection route crosses two shallow, artificial canals. Installation of the 

interconnections through the canals most likely will be by open-cut methods. These in-stream 

construction techniques will cause a short-term increase in turbidity, but because these canals 

are artificial and the environment is regularly subjected to the disturbance of heavy water flow, 

the short-term turbidity of these activities is unlikely to have lasting effects. 

6.2 Impacts to the Estuarine Component of the EFH 

The Bayou Casotte shipping channel is dredged regularly (approximately every three years), by 

the USACE; therefore, the benthic community that proliferates in this frequently disturbed, 

organically enriched environment is well adapted to these conditions. The benthic infaunal 

community is dominated by opportunistic species that recolonize their habitat rapidly. Typical 

species found in this habitat include Heteromastis filiformis, Capitella capitata, Streblospio 

benedicti, Paraprionospio pinnata, and Mulinia lateralis. Dredging would be the principal impact 

to benthic species. The next section discusses primary dredging impacts to EFH. 

6.2.1 Primary Dredging Impact 

A small section of shoreline and unvegetated benthic habitat adjacent to the lower portion of 

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22 September 2005 

Bayou Casotte will be permanently altered by this Project. The excavated slip will disturb an 

area of unvegetated shoreline and benthic habitat in Bayou Casotte and would remove 

approximately 4.5 million cubic yards of material. Approximately 1 million cubic yards of 

material will be excavated from above the water table. The total slip area, including the portion 

landward of the shoreline, is approximately 55.3 acres. The dredging required to connect the 

slip to the existing navigational channel will result in the removal of approximately 338,000 cubic 

yards within an area of approximately 275,000 square feet (6.3 acres). A temporary loss of food 

supply for finfish and crustaceans could occur during construction. However, the dredging will 

oxidize nutrient-rich sediments and could stimulate recolonization in areas that are hypoxic and 

improve habitat for benthic polychaetes, mollusks, and crustaceans, which in turn provide 

forage for opportunistic benthic finfish and shrimp species. Although dredging will disturb 

approximately 6.3 acres of unvegetated benthic habitat from this heavily industrialized, regularly 

disturbed shipping channel, the benthic community will recolonize the impacted area rapidly and 

the long-term impacts to marine substrates, benthic communities and fisheries are anticipated to 

be insignificant. Creation of the slip will result in the creation of additional unvegetated benthic 

habitat (i.e., the double-berth slip, which will create approximately 49.0 acres of new benthic 

habitat). Appropriate Best Management Practices will be employed as necessary to be certain 

that potential impacts to EFH and to threatened and endangered species are minimized. 

6.2.2 Turbidity Impacts 

Bayou Casotte is a turbid estuary with background levels of approximately 15–20 NTUs. Based 

on worst-case scenario modeling results, mechanical dredging will not significantly increase the 

turbidity in Bayou Casotte above background levels, and no secondary (turbidity) impacts are 

anticipated. Please refer to Resource Report 2 of this ER for turbidity plume modeling, increase 

in NTUs, and dispersion rates. The increase in sediment turbidity during construction will be 

temporary. Modeling shows that the dredging will not increase turbidity significantly above 

background levels and the suspended sediments will redeposit upon completion of construction 

activities. Little increase above background sediment load is anticipated and none of the 

species listed with EFH in the Bayou Casotte vicinity deposit fertilized eggs in this habitat, so 

the possibility that deposition of suspended sediments could smother demersal eggs and larvae 

is remote. Red drum is the only species listed with EFH for larvae in Bayou Casotte, the larvae 

of this species is pelagic. Sedentary demersal fishes are unlikely to be affected by the low, 

temporary increase in sediment turbidity within the water column during construction. Figure 

6.2.2-1 shows the results taken from Resource Report 2 of this ER. Total suspended solids 

(TSS) would have highest concentrations within 0-25 m from the dredging activities. By 50 m 

from the dredging operations TSS is reduced to below normal background values found in 

Bayou Casotte. 

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23 September 2005 

0

5

10

15

20

25

0 200 400 600 800 1000

Distance (m)

Maximum TSS 

Concentration (mg/L)

FIGURE 6.2.2-1 MAXIMUM TSS CONCENTRATION IN RELATION TO DISTANCE BASED 

ON DREDGE MODEL. 

Potential sediment resuspension related to mechanical dredging of the slip material has been 

evaluated using the DREDGE model developed by the USACE. Model parameters were 

selected from a recent investigation (Hayes and Je, 2000; USACE, 2001) using aggressive 

operational tactics. Based on this simulation, the total suspended solids (TSS) generated by the 

mechanical dredge over a 1,000-m distance from the source is expected to average 6.7 

milligrams per liter (mg/L). A maximum of 19.9 mg/L would be expected at the dredging source, 

itself, which is within the range of background values for Bayou Casotte turbidity. TSS 

generated from dredging operations would not likely produce a detectable turbidity plume, and 

the turbidity impacts of dredging are anticipated to be insignificant. 

Maintenance dredging of the slip will be conducted according to federal, state, and local 

regulations and permits. Preliminary modeling suggests that maintenance dredging will be 

required every 12 to 36 months. The volume of maintenance dredging has been calculated to 

be 250,000 cy/year. This material will be disposed of in a manner acceptable to federal, state, 

and local agencies. Although turbidity will increase during dredging, it will not be significantly 

above background levels. 

It is anticipated that the adult stages of most demersal and pelagic finfish species will avoid 

construction areas, and that potential impacts will be temporary and minor resulting in the 

displacement of, followed by rapid post-construction re-colonization by these species. 

Although vessel operations may result in prop wash and erosion, which may impact EFH, vessel 

operations including transit to and from the slip will be in the existing federal channel located 

hundreds of feet from shorelines. Any prop wash, wakes, or surges from these operations 

would not be measurably different than that from other vessel traffic in the channel and have 

negligible impact to the shorelines compared to wave or tidal induced impacts. Erosion within 

the slip from vessel passage or prop wash will be controlled by the installation of appropriate 

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scour protection, such as stone riprap, and no significant erosion or impact to EFH is expected 

to occur. 

6.2.3 Submerged Aquatic Vegetation and Shellfish Beds

Many juvenile fish species utilize estuarine SAV as habitat, but seagrasses do not grow in the 

silty sediment and turbid waters of the Project location, so no impacts are anticipated. 

There are no known oyster beds in the vicinity of the Project site, therefore these resources will 

not be impacted by dredging or re-suspended sediments. 

6.2.4 Potential for Offshore Spills 

Another category of impacts to estuarine fish and wildlife is the potential for accidental spills of 

material during construction or operations. These spills could originate from: accidental spills 

from construction barges or support boats, loss of fuel during fuel transfers, or accidents 

resulting from collisions. Construction will involve a significant amount of work activity aboard 

vessels and other specialized marine equipment. Bayou Casotte Energy and their construction 

contractors will comply with all laws and regulations related to handling of fuels and lubricants, 

including 40 CFR 110, and related to vessel-to-vessel transfers, including 33 CFR 155. 

6.2.5 Summary of EFH Impacts 

Because Bayou Casotte does not support commercial fisheries other than occasional crab 

harvest during appropriate seasons, impacts to the commercial fisheries resources from this 

project are expected to be minimal. Local recreational fishing will not be impacted as fish will be 

able to move back into the habitat after construction is completed. 

Potential impingement and entrainment impact must be considered for any project in areas of 

high fish egg and larvae abundance. The Project’s regasification system will utilize “closedloop” technology (i.e., no water intake from the ambient environment will be used for the regasification process), which eliminates the potential for impingement and entrainment mortality 

for normal regasification processes. The only water intake associated with the Project is part of 

shipping operations (ship’s cooling water and ship’s ballast water). The relatively low volumes 

of water associated with these activities ensure that impacts will be negligible. Impingement 

and entrainment impacts related to shipping operations are discussed within Resource Report 3 

of this ER. 

The EFH impact evaluation process for the Project is summarized below in Table 6.2-1. 

Impacts are listed by type and nature (i.e., significance of effects). Impacts are considered 

direct, indirect, temporary, short-term, long-term, permanent, and/or cumulative. 

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TABLE 6.2-1. SUMMARY OF POTENTIAL IMPACTS TO EFH BY IMPACT TYPE 

Type of Impact 

Temporary 

[Recovery 

Days to 

Weeks] 

Short Term 

[Recovery 

<3 Years] 

Long Term

[Recovery 

>3 to <20 

Years] 

Permanent 

[Recovery 

>20 Years] Cumulative

Barge Anchoring 9 

Sedimentation/Turbidity1 9 

Disruption of Soft Substrate 9 

Seafloor Area Occupied* 9

Epifauna/Infauna 

Destruction 

9 

Fish Fauna Disruption 

Species 

9 

Fish Fauna Disruption 

Habitat 

9 

Reduction Water Quality/ 

Spills, Mud discharges 

9 

* area permanently altered 

1 Sediment turbidity associated with LNG Vessel passage is temporary in nature but will be ongoing 

throughout the year. 

Most of the above effects are temporary and will be offset by special construction techniques or 

environmental protection guidelines, or are negligible considering the degraded, industrialized 

state of the habitat near the Project site and the localized effect of the actions compared to the 

area of the Gulf of Mexico that will be unaffected. The proposed action will have minor effects 

on designated EFH or commercial fisheries. Recovery of EFH and commercial fisheries is 

expected to occur quickly (one growing season) for the affected environment. 

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7.0 PROPOSED MITIGATIVE MEASURES 

Onshore wetland habitat that is impacted will be mitigated according to a mitigation plan/ratio 

currently being discussed with the USACE, MDMR, and other applicable agencies (through 

team permitting). Wetlands that would be potentially impacted by this Project that serve as EFH 

will be included within the finalized mitigation plan. EFH will be mitigated “in-kind”; no artificial 

reefs will be created as no artificial or natural reefs will be impacted by this Project. The primary 

source of impact to the marine environment is from dredging. The primary impact area is the 

6.3 acres of unvegetated benthic habitat that will be disturbed to connect the slip to the shipping 

channel. The opportunistic benthic species in Bayou Casotte will quickly recolonize this area. 

The permanent creation of similar unvegetated benthic habitat in the double-berth slip will more 

than offset this temporary disturbance. Because the habitat is naturally turbid and sediment 

models predict that the dredging for construction and maintenance will not increase turbidity 

significantly above background, no impacts to EFH are predicted. 

Consultation with NMFS is ongoing, and results will be communicated to FERC upon 

completion. Correspondence and communications indicate that significant adverse impacts to 

fisheries from this Project are unlikely; however, Bayou Casotte Energy has incorporated 

several strategies to minimize potential impacts to EFH: 

• To prevent the introduction of exotic and/or invasive species in ballast water, on ship 

hulls, and anchors/chains, vessels calling on Casotte Landing will be required to follow 

the USCG Office of Operating and Environmental Standards 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 remove fouling organisms from 

hull, piping, and tanks on a regular basis and dispose of any removed substances in 

accordance with federal, state, and local regulations. Vessels will be required to comply 

with these requirements and to keep records documenting their compliance. 

• Best Management Practices (BMPs) such as hay bales and silt fence will be strategically 

placed per Bayou Casotte Energy’s Plan and Procedures to prevent siltation from shoreside construction from entering the estuarine environment. 

• Bayou Casotte Energy analyzed the ELMR records of seasonable abundance to 

determine whether scheduling construction for seasons of low abundance was possible. 

These records indicate that, for the six species considered common to Bayou Casotte, 

eggs, larvae, and/or juveniles of at least one species are present throughout the year. 

Consultations with NMFS to refine the dredging schedule are ongoing. 

• Bayou Casotte Energy has avoided oyster reefs and seagrass beds by careful site 

selection. 

• Whenever possible, excavated materials will be stored and contained on uplands. 

• Utilization of cooling water from industrial sources and “closed-loop” technology will 

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27 September 2005 

greatly reduce impacts to EFH that would otherwise be generated in the form of 

impingement and entrainment. The arrangement that has been established between 

Bayou Casotte Energy and Pascagoula Refinery to take the Refinery’s warmed 

wastewater and use it for the warming regasification process is a unique mitigation 

measure. 

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8.0 CONCLUSIONS 

The Project site was selected because it is among other industrialized locations along Bayou 

Casotte. It is important to note that the existing habitat at the Project location is 

anthropogenically impacted, frequently dredged, and highly turbid. This habitat, despite 

alterations, will remain estuarine and will be utilized by fish that return to the area after 

construction is completed. Locating the Terminal adjacent to the existing Pascagoula Refinery 

presents the unique opportunity to use its waste heat in the Terminal’s regasification system, 

thereby eliminating the environmental impacts associated with water exchange (e.g., in open 

rack vaporizer systems). 

In general, direct and indirect impacts to EFH for managed species will be temporary. The 

primary impacts will be disturbance of unvegetated benthic habitat. The Bayou Casotte benthic 

community is well adapted to dredging disturbance. These opportunistic species are expected 

to recolonize the area within one growing season. The temporary, minor impairment of water 

quality due to turbidity and suspended-solid concentrations during dredging in the shallow, 

estuarine water adjacent to the Project site will not be significantly above ambient conditions, 

nor will that caused by the passing of LNG vessels. Overall, the Project is not anticipated to 

have adverse or lasting impacts to EFH. 

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29 September 2005 

9.0 REFERENCES CITED 

Barry A. Vittor & Associates, Inc. 1985. Tuscaloosa Trend Regional Data Search and Synthesis 

Study (Volume I-Synthesis Report). Final report submitted to Minerals Management 

Service, Metairie, LA. Contract No. 14-12-0001-30048. xxvi + 477 pp. 

Byrnes, M.R., R.M. Hammer, B.A. Vittor, J.S. Ramsey, D.B. Snyder, K.F. Bosma, J.D. Wood, 

T.D. Thibaut, N.W. Phillips, 1999. Environmental Survey of Identified Sand Resource 

Areas Offshore Alabama: Volume I: Main Text, Volume II: Appendices. U.S. Department 

of Interior, Minerals Management Service, International Activities and Marine Minerals 

Division (INTERMAR), Herndon, VA. OCS Report MMS 99-0052, 326 pp. + 132 pp. 

appendices. 

Gulf of Mexico Fisheries Management Council. 2004. Final Environmental Impact Statement for 

the Generic Essential Fish Habitat Amendment. Vol. I. 682 pp + appendices. 

Hayes, D.F. and C. Je. 2000. DRAFT DREDGE Module User’s Guide. Department of Civil and 

Environmental Engineering, University of Utah. 

Hayes, D.F. and P. Wu. 2001. Simple Approach to TSS Source Strength Estimates. Western 

Dredging Association (WEDA) Proceedings, WEDA XXI, Houston, TX, June 25-27, 

2001. 

National Marine Fisheries Service. 2005. Telephone conversation with Mark Thompson (NMFS) 

Please see correspondence included in this ER. 

National Marine Fisheries Service. 2002. Essential Fish Habitat: A Marine Fish Habitat 

Conservation Mandate for Federal Agencies, Gulf of Mexico Region. 17 pp. 

National Oceanic and Atmospheric Administration (NOAA). 2005. Estuarine Living Marine 

Resources (ELMR) Data Base. http://biogeo.nos.noaa.gov/products/elmr/ 

Patillo, M. E., T. E. Czapla, D. M. Nelson and M. E. Monaco, 1997 Distribution and abundance 

of fishes and invertebrates in Gulf of Mexico estuaries. Vol. II. Species life history 

summaries. ELMR Rep. No. 11. NOAA/NOS Strategic Environmental Assessments 

Division, Silver Springs, MD 

Perret, W.S., J.E. Weaver, R.O. Williams, P.L. Johansen, T.D. McIlwain, R.C. Raulcrson, and 

W.M. Tatum. 1980. Fishery profiles of red drum and spotted seatrout. Gulf States Marine 

Fisheries Commission Report No. 6. 

Rhoads, D.C. and J.D. Germano, 1982. Characterization of organism-sediment relations using 

sediment profile imaging: An efficient method of remote ecological monitoring of the 

seafloor (REMOTSTM System). Marine Ecology Progress Series, 8: 115-128. 

Rhoads, D.C.,1974. Organism-sediment relations on the muddy seafloor. In H. Barnes, ed. 

Oceanographic and Marine Biological Annual Reviews. Vol 12: 263-300. 

Shaw, J.K., P.G. Johnson, R.M. Ewing, C.E. Comiskey, C.C. Brant, and T.A. Farmer. 1982. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Appendix 3–A Casotte Landing Natural Gas 

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30 September 2005 

Benthic macroinfauna community characterization in Mississippi Sound and adjacent 

waters. U.S. Army Corps of Engineers, Mobile District, Mobile, AL. 442 pp. 

Stickle, W.B., M.A. Kapper, L. Liu, E. Gnaiger, and S.Y. Wang, 1989. Metabolic adaptation of 

several species of crustaceans and mollusks to hypoxia: Tolerance and 

microcalorimetric studies. Biological Bulletin, 177: 301-312. 

U.S. Army Corps of Engineers (USACE). 2001. Providence River and Harbor Maintenance 

Dredging Project Final Environmental Impact Statement. August. 

U.S. Geological Survey (USGS) – National Wetlands Research Center (NWRC). 2003. GIS 

Database. 1992 Mississippi Sound, MS Submerged Aquatic Vegetation Data. 

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Appendix 3–A–A 

NOAA Estuarine Living Marine Resources (ELMR) Database Query for Mississippi Sound 

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Essential Fish Habitat Assessment Impo 1 Table 1. Life stages of Atlantic Brief Squid found within Missippi Sound during each month and under various salinity conditions. DaNOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 2 2 2 3 3 3 3 3 3 3 SPAWNING 15-25 ppt 2 2 2 3 3 3 3 3 3 3 SPAWNING >25 ppt 2 2 2 3 3 3 3 3 3 3 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 2 2 2 2 2 2 2 LARVAE 5-15 ppt 2 2 2 3 3 3 3 3 3 3 LARVAE 15-25 ppt 2 2 2 3 3 3 3 3 3 3 LARVAE >25 ppt 2 2 2 3 3 3 3 3 3 3 JUVENILES 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 4 4 4 4 4 4 4 JUVENILES >25 ppt 3 3 4 4 4 4 4 4 4 4 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 2 2 2 2 2 2 2 EGGS 5-15 ppt 2 2 2 3 3 3 3 3 3 3 EGGS 15-25 ppt 2 2 2 3 3 3 3 3 3 3 EGGS >25 ppt 2 2 2 3 3 3 3 3 3 3 ADULTS 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 2 Table 2. Life stages of Atlantic Croaker found within Missippi Sound during each month and under various salinity conditions. Data 

downloaded from NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October 

SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 2 2 2 2 0 0 0 2 2 2 LARVAE 5-15 ppt 3 3 3 2 0 0 0 2 3 3 LARVAE 15-25 ppt 3 3 3 2 0 0 0 2 3 3 LARVAE >25 ppt 3 3 3 2 0 0 0 2 3 3 JUVENILES 0-0.5 ppt 3 3 4 4 4 4 4 4 4 4 JUVENILES 0.5-5 ppt 4 4 5 5 5 5 4 4 4 4 JUVENILES 5-15 ppt 4 4 5 5 5 5 4 4 4 4 JUVENILES 15-25 ppt 4 4 5 5 5 5 4 4 4 4 JUVENILES >25 ppt 4 4 5 5 5 4 4 4 4 4 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 2 2 2 2 0 0 0 0 2 2 ADULTS 0-0.5 ppt 2 2 2 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 2 2 3 3 3 3 4 4 4 4 ADULTS 5-15 ppt 3 3 3 3 3 3 4 4 4 4 ADULTS 15-25 ppt 3 3 3 3 3 3 4 4 4 4 ADULTS >25 ppt 3 3 3 3 3 3 4 4 4 4 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
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Essential Fish Habitat Assessment Impo 3 Table 3. Life stages of Atlantic Rangia found within Missippi Sound during each month and under various salinity conditions. Data downloaded from NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 3 3 2 0 0 2 3 3 SPAWNING 5-15 ppt 0 0 3 3 2 0 0 2 3 3 SPAWNING 15-25 ppt 0 0 2 2 2 0 0 2 2 2 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 2 2 . . . . . . LARVAE 0.5-5 ppt 0 0 3 3 3 2 2 2 3 3 LARVAE 5-15 ppt 0 0 3 3 3 2 2 2 3 3 LARVAE 15-25 ppt 0 0 2 2 2 2 2 2 2 2 LARVAE >25 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 3 3 2 2 2 2 3 3 EGGS 5-15 ppt 0 0 3 3 2 2 2 2 3 3 EGGS 15-25 ppt 0 0 3 3 2 2 2 2 2 2 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 0 0 0 0 0 0 0 0 0 0 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 4 Table 4. Life stages of the Bay Anchovy found within Missippi Sound during each month and under various salinity conditions. Data downloaded from NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 3 4 3 . . . . . . SPAWNING 0.5-5 ppt 2 2 3 4 5 5 5 5 5 4 SPAWNING 5-15 ppt 2 2 3 4 5 5 5 5 5 4 SPAWNING 15-25 ppt 2 2 3 4 5 5 5 5 5 4 SPAWNING >25 ppt 2 2 3 4 4 4 4 4 4 4 LARVAE 0-0.5 ppt . 0 0 2 . . . . . . LARVAE 0.5-5 ppt 2 2 3 4 5 5 5 5 5 4 LARVAE 5-15 ppt 2 2 3 4 5 5 5 5 5 4 LARVAE 15-25 ppt 2 2 3 4 5 5 5 5 5 4 LARVAE >25 ppt 2 2 3 4 4 4 4 4 4 4 JUVENILES 0-0.5 ppt 4 4 4 4 4 4 4 4 4 4 JUVENILES 0.5-5 ppt 4 4 5 5 5 5 5 5 5 5 JUVENILES 5-15 ppt 4 4 5 5 5 5 5 5 5 5 JUVENILES 15-25 ppt 4 4 5 5 5 5 5 5 5 5 JUVENILES >25 ppt 4 4 5 5 5 4 4 4 4 4 EGGS 0-0.5 ppt . 0 0 2 . . . . . . EGGS 0.5-5 ppt 2 2 3 4 5 5 5 5 5 4 EGGS 5-15 ppt 2 2 3 4 5 5 5 5 5 4 EGGS 15-25 ppt 2 2 3 4 5 5 5 5 5 4 EGGS >25 ppt 2 2 3 4 4 4 4 4 4 4 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 4 4 5 5 5 5 5 5 5 ADULTS 5-15 ppt 4 4 4 5 5 5 5 5 5 5 ADULTS 15-25 ppt 4 4 4 5 5 5 5 5 5 5 ADULTS >25 ppt 4 4 5 5 5 4 4 4 4 4 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 5 Table 5. Life stages of the Bay Scallop found within Missippi Sound during each month and under various salinity conditions. Data 

downloaded from NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October 

SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 3 3 3 SPAWNING >25 ppt 0 0 0 0 0 0 0 3 3 3 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 2 2 2 LARVAE 5-15 ppt 0 0 0 0 0 0 0 3 3 3 LARVAE 15-25 ppt 0 0 0 0 0 0 0 3 3 3 LARVAE >25 ppt 0 0 0 0 0 0 0 3 3 3 JUVENILES 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 5-15 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 3 3 3 EGGS 15-25 ppt 0 0 0 0 0 0 0 3 3 3 EGGS >25 ppt 0 0 0 0 0 0 0 3 3 3 ADULTS 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 6 Table 6. Life stages of the Black Drum found within Missippi Sound during each month and under various salinity conditions. Data 

downloaded from NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October 

SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 3 3 3 3 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 2 2 2 0 0 0 0 0 0 LARVAE 5-15 ppt 2 3 3 3 0 0 0 0 0 0 LARVAE 15-25 ppt 2 3 3 3 0 0 0 0 0 0 LARVAE >25 ppt 2 3 3 3 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 2 3 3 3 0 0 0 0 0 0 ADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 7 Table 7. Life stages of the Blue Crab found within Missippi Sound during each month and under various salinity conditions. Data downloaded from NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 2 3 3 . . . . . . SPAWNING 0.5-5 ppt 2 2 3 4 5 5 5 5 5 4 SPAWNING 5-15 ppt 2 2 3 4 4 4 4 4 4 4 SPAWNING 15-25 ppt 2 2 3 3 3 3 3 3 3 3 SPAWNING >25 ppt 2 2 2 2 2 2 2 2 2 2 LARVAE 0-0.5 ppt . 0 0 2 . . . . . . LARVAE 0.5-5 ppt 2 2 3 3 3 3 3 3 3 3 LARVAE 5-15 ppt 2 2 3 4 4 4 4 4 4 4 LARVAE 15-25 ppt 2 2 3 4 5 5 5 5 5 5 LARVAE >25 ppt 3 3 3 4 5 5 5 5 5 5 JUVENILES 0-0.5 ppt 4 4 3 3 3 5 5 5 5 5 JUVENILES 0.5-5 ppt 4 4 3 3 3 5 5 5 5 5 JUVENILES 5-15 ppt 4 4 3 3 3 5 5 5 5 5 JUVENILES 15-25 ppt 4 4 3 3 3 5 5 5 5 5 JUVENILES >25 ppt 4 4 3 3 3 5 5 5 5 5 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 2 2 3 3 3 3 3 3 3 3 EGGS 5-15 ppt 2 2 3 4 4 4 4 4 4 4 EGGS 15-25 ppt 2 2 3 4 5 5 5 5 5 4 EGGS >25 ppt 2 2 3 4 5 5 5 5 5 4 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 3 3 4 4 4 4 4 4 4 ADULTS 5-15 ppt 3 3 3 4 4 4 4 4 4 4 ADULTS 15-25 ppt 3 3 3 4 4 4 4 4 4 4 ADULTS >25 ppt 3 3 3 4 4 4 4 4 4 4 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 8 Table 8. Life stages of the Blue Runner found within Missippi Sound during each month and under various salinity conditions. Data downloaded from NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 15-25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE >25 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 5-15 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 15-25 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES >25 ppt 2 2 2 2 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 15-25 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS >25 ppt 2 2 2 2 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 9 Table 9. Life stages of the Bluefish found within Missippi Sound during each month and under various salinity conditions. Data downloaded from NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 15-25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE >25 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 2 2 2 2 3 3 3 3 2 2 JUVENILES 5-15 ppt 2 2 2 2 3 3 3 3 2 2 JUVENILES 15-25 ppt 2 2 2 3 3 3 3 3 3 2 JUVENILES >25 ppt 2 2 3 3 4 4 4 4 4 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 5-15 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 15-25 ppt 2 2 3 3 3 3 3 3 3 3 ADULTS >25 ppt 2 2 3 3 4 4 4 4 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 10 Table 10. Life stages of the Brown Shrimp found within Missippi Sound during each month and under various salinity conditions.Data downloaded from NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 2 2 2 2 2 2 2 2 2 2 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 2 4 4 4 4 4 4 3 3 3 LARVAE 5-15 ppt 2 5 5 5 4 4 4 4 4 3 LARVAE 15-25 ppt 2 5 5 5 4 4 4 4 4 3 LARVAE >25 ppt 2 5 5 5 4 4 4 4 4 3 JUVENILES 0-0.5 ppt 3 3 3 4 5 5 4 4 4 3 JUVENILES 0.5-5 ppt 3 3 3 4 5 5 4 4 4 3 JUVENILES 5-15 ppt 3 3 3 4 5 5 4 4 4 3 JUVENILES 15-25 ppt 3 3 3 4 5 5 4 4 4 3 JUVENILES >25 ppt 3 3 3 4 5 5 4 4 4 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 5-15 ppt 2 2 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 4 4 4 3 3 ADULTS >25 ppt 3 3 3 3 3 4 4 4 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 11 Table 11. Life stages of the Bull Shark found within Missippi Sound during each month and under various salinity conditions. Data downloaded from NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 3 3 2 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 3 3 2 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 3 3 2 0 0 SPAWNING >25 ppt 0 0 0 0 0 3 3 2 0 0 LARVAE 0-0.5 ppt . 0 0 2 . . . . . . LARVAE 0.5-5 ppt 0 0 0 2 3 3 3 2 0 0 LARVAE 5-15 ppt 0 0 0 2 3 3 3 2 0 0 LARVAE 15-25 ppt 0 0 0 2 3 3 3 2 0 0 LARVAE >25 ppt 0 0 0 2 3 3 3 2 0 0 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 2 2 2 3 3 3 2 2 2 2 ADULTS 0.5-5 ppt 2 2 3 3 3 3 3 3 3 2 ADULTS 5-15 ppt 2 2 3 3 3 3 3 3 3 2 ADULTS 15-25 ppt 2 2 3 3 3 3 3 3 3 2 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 12 Table 12. Life stages of the Code Goby found within Missippi Sound during each month and under various salinity conditions. Data d

Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October 

SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 2 2 2 2 2 0 0 SPAWNING 15-25 ppt 2 2 2 3 3 3 3 3 2 2 SPAWNING >25 ppt 2 2 2 3 3 3 3 3 2 2 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 0 2 2 2 2 2 2 0 LARVAE 15-25 ppt 2 2 2 3 3 3 3 3 2 2 LARVAE >25 ppt 2 2 2 3 3 3 3 3 2 2 JUVENILES 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 2 2 2 2 2 2 0 EGGS 15-25 ppt 2 2 2 3 3 3 3 3 2 2 EGGS >25 ppt 2 2 2 3 3 3 3 3 2 2 ADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 13 Table 13. Life stages of the Crevalle Jack found within Missippi Sound during each month and under various salinity conditions. Data NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 15-25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE >25 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 0 0 0 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 0 0 2 2 3 3 3 3 3 3 JUVENILES 5-15 ppt 0 0 2 2 3 3 3 3 3 3 JUVENILES 15-25 ppt 0 0 2 2 3 3 3 3 3 3 JUVENILES >25 ppt 0 0 2 2 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0.5-5 ppt 0 0 2 2 3 3 3 3 3 3 ADULTS 5-15 ppt 0 0 2 2 3 3 3 3 3 3 ADULTS 15-25 ppt 0 0 2 2 3 3 3 3 3 3 ADULTS >25 ppt 0 0 2 2 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 14 Table 14. Life stages of the Daggerblade Grass Shrimp found within Missippi Sound during each month and under various salinity confrom NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 3 3 3 3 3 3 3 3 SPAWNING 5-15 ppt 0 0 3 4 5 5 4 4 5 5 SPAWNING 15-25 ppt 0 0 3 4 5 5 4 4 5 5 SPAWNING >25 ppt 0 0 3 4 5 5 4 4 5 5 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 3 3 3 3 3 3 3 3 LARVAE 5-15 ppt 0 0 3 4 5 5 4 4 5 5 LARVAE 15-25 ppt 0 0 3 4 5 5 4 4 5 5 LARVAE >25 ppt 0 0 3 3 3 3 3 3 3 3 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 4 4 4 4 4 4 4 4 4 4 JUVENILES 5-15 ppt 4 4 4 4 4 4 4 4 4 4 JUVENILES 15-25 ppt 4 4 4 4 4 4 4 4 4 4 JUVENILES >25 ppt 4 4 4 4 4 4 4 4 4 4 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 3 3 3 3 3 3 3 3 EGGS 5-15 ppt 0 0 3 4 5 5 4 4 5 5 EGGS 15-25 ppt 0 0 3 4 5 5 4 4 5 5 EGGS >25 ppt 0 0 3 3 3 3 3 3 3 3 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 4 4 4 4 4 4 4 4 4 4 ADULTS 5-15 ppt 4 4 4 4 4 4 4 4 4 4 ADULTS 15-25 ppt 4 4 4 4 4 4 4 4 4 4 ADULTS >25 ppt 4 4 4 4 4 4 4 4 4 4 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 15 Table 15. Life stages of the Eastern Oyster found within Missippi Sound during each month and under various salinity conditions. Da

NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October 

SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 3 4 4 4 4 4 4 4 SPAWNING 5-15 ppt 0 0 3 4 4 4 4 4 4 4 SPAWNING 15-25 ppt 0 0 3 4 4 4 4 4 4 4 SPAWNING >25 ppt 0 0 2 3 3 3 3 3 3 3 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 3 4 4 4 4 4 4 4 LARVAE 5-15 ppt 0 0 3 4 4 4 4 4 4 4 LARVAE 15-25 ppt 0 0 3 4 4 4 4 4 4 4 LARVAE >25 ppt 0 0 3 4 4 4 4 4 4 4 JUVENILES 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 4 4 4 4 4 4 4 4 4 4 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 2 2 2 2 2 2 2 2 2 2 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 3 4 4 4 4 4 4 4 EGGS 5-15 ppt 0 0 3 4 4 4 4 4 4 4 EGGS 15-25 ppt 0 0 3 4 4 4 4 4 4 4 EGGS >25 ppt 0 0 2 3 3 3 3 3 3 3 ADULTS 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 4 4 4 4 4 4 4 4 4 4 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 2 2 2 2 2 2 2 2 2 2 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 16 Table 16. Life stages of the Florida Pompano found within Missippi Sound during each month and under various salinity conditions. DNOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 15-25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE >25 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 5-15 ppt 0 0 0 2 2 2 2 2 2 2 JUVENILES 15-25 ppt 0 0 2 2 2 2 2 2 2 2 JUVENILES >25 ppt 0 0 0 2 3 3 3 3 3 2 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 5-15 ppt 0 0 0 2 2 2 2 2 2 2 ADULTS 15-25 ppt 0 0 0 2 3 3 3 3 3 2 ADULTS >25 ppt 0 0 0 2 3 3 3 3 3 2 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 17 Table 17. Life stages of the Gizzard Shad found within Missippi Sound during each month and under various salinity conditions. Data NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 3 3 . . . . . . SPAWNING 0.5-5 ppt 0 0 2 2 2 2 2 2 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 3 3 . . . . . . LARVAE 0.5-5 ppt 0 0 2 2 2 2 2 2 2 0 LARVAE 5-15 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 15-25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE >25 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES >25 ppt 2 2 2 2 2 2 2 2 2 2 EGGS 0-0.5 ppt . 0 3 3 . . . . . . EGGS 0.5-5 ppt 0 0 2 2 2 2 2 2 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS >25 ppt 2 2 2 2 2 2 2 2 2 2 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 18 Table 18. Life stages of the Gray Snapper found within Missippi Sound during each month and under various salinity conditions. Data NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 15-25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE >25 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 5-15 ppt 2 2 2 2 2 3 3 3 3 3 JUVENILES 15-25 ppt 2 2 2 2 2 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 5-15 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 15-25 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS >25 ppt 2 2 2 2 2 2 2 2 2 2 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 19 Table 19. Life stages of the Gulf Flounder found within Missippi Sound during each month and under various salinity conditions. Dat

NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October 

SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 2 2 2 0 0 0 0 0 0 0 LARVAE 15-25 ppt 3 3 3 0 0 0 0 0 0 0 LARVAE >25 ppt 3 3 3 0 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 5-15 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 15-25 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES >25 ppt 2 2 2 2 2 2 2 2 2 2 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 2 2 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 5-15 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 15-25 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS >25 ppt 2 2 2 2 2 2 2 2 2 2 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 20 Table 20. Life stages of the Gulf Killifish found within Missippi Sound during each month and under various salinity conditions. Data 

NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October 

SPAWNING 0-0.5 ppt . 2 2 2 . . . . . . SPAWNING 0.5-5 ppt 2 2 2 3 3 3 3 3 3 2 SPAWNING 5-15 ppt 2 2 2 3 3 3 3 3 3 2 SPAWNING 15-25 ppt 2 2 2 3 3 3 3 3 3 2 SPAWNING >25 ppt 2 2 2 3 3 3 3 3 3 2 LARVAE 0-0.5 ppt . 2 2 2 . . . . . . LARVAE 0.5-5 ppt 2 2 2 3 3 3 3 3 3 2 LARVAE 5-15 ppt 2 2 2 3 3 3 3 3 3 2 LARVAE 15-25 ppt 2 2 2 3 3 3 3 3 3 2 LARVAE >25 ppt 2 2 2 3 3 3 3 3 3 2 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 2 2 2 . . . . . . EGGS 0.5-5 ppt 2 2 2 3 3 3 3 3 3 2 EGGS 5-15 ppt 2 2 2 3 3 3 3 3 3 2 EGGS 15-25 ppt 2 2 2 3 3 3 3 3 3 2 EGGS >25 ppt 2 2 2 3 3 3 3 3 3 2 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 21 Table 21. Life stages of the Gulf Menhaden found within Missippi Sound during each month and under various salinity conditions. DaNOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 15-25 ppt 2 2 2 2 0 0 0 2 2 2 LARVAE >25 ppt 5 5 4 3 0 0 0 2 3 4 JUVENILES 0-0.5 ppt 5 5 3 4 4 4 4 4 4 3 JUVENILES 0.5-5 ppt 5 5 3 4 5 5 5 5 4 3 JUVENILES 5-15 ppt 5 5 3 4 5 5 5 5 4 3 JUVENILES 15-25 ppt 5 5 3 4 5 5 5 5 4 3 JUVENILES >25 ppt 5 5 3 4 5 5 5 5 4 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 3 3 2 2 0 0 0 0 2 2 ADULTS 0-0.5 ppt 0 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 3 3 3 3 3 5 5 5 4 3 ADULTS 5-15 ppt 3 3 3 3 3 5 5 5 4 3 ADULTS 15-25 ppt 3 3 3 3 3 5 5 5 4 3 ADULTS >25 ppt 3 3 3 3 3 5 5 5 4 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 22 Table 22. Life stages of the Gulf Stone Crab found within Missippi Sound during each month and under various salinity conditions. D

NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October 

SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 3 3 3 2 0 0 0 0 2 3 SPAWNING 15-25 ppt 3 3 3 2 0 0 0 0 2 3 SPAWNING >25 ppt 3 3 3 2 0 0 0 0 2 3 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 2 3 3 3 3 3 3 2 LARVAE 15-25 ppt 0 0 2 3 3 3 3 3 3 2 LARVAE >25 ppt 0 0 2 3 3 3 3 3 3 2 JUVENILES 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 2 3 3 3 3 3 3 2 EGGS 15-25 ppt 0 0 2 3 3 3 3 3 3 2 EGGS >25 ppt 0 0 2 3 3 3 3 3 3 2 ADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 5-15 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 23 Table 23. Life stages of the Gulf Sturgeon found within Missippi Sound during each month and under various salinity conditions. Dat

NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October 

JUVENILES 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 5-15 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 15-25 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES >25 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 5-15 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 15-25 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS >25 ppt 2 2 2 2 2 2 2 2 2 2 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 24 Table 24. Life stages of the Hardhead Catfish found within Missippi Sound during each month and under various salinity conditions. DNOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 2 3 3 3 3 3 2 SPAWNING 5-15 ppt 0 0 0 2 3 4 4 4 3 2 SPAWNING 15-25 ppt 0 0 0 2 3 4 4 4 3 2 SPAWNING >25 ppt 0 0 0 2 3 4 4 4 3 2 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 2 3 3 3 3 3 2 LARVAE 5-15 ppt 0 0 0 2 3 4 4 4 3 2 LARVAE 15-25 ppt 0 0 0 2 3 4 4 4 3 2 LARVAE >25 ppt 0 0 0 2 3 4 4 4 3 2 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 3 3 3 4 4 4 4 4 4 4 JUVENILES 5-15 ppt 3 3 3 4 4 4 4 4 4 4 JUVENILES 15-25 ppt 3 3 4 4 4 4 4 4 4 4 JUVENILES >25 ppt 3 3 4 4 4 4 4 4 4 4 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 2 3 3 3 3 3 2 EGGS 5-15 ppt 0 0 0 2 3 4 4 4 3 2 EGGS 15-25 ppt 0 0 0 2 3 4 4 4 3 2 EGGS >25 ppt 0 0 0 2 3 4 4 4 3 2 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 3 3 4 4 4 4 4 4 4 ADULTS 5-15 ppt 3 3 3 4 4 4 4 4 4 4 ADULTS 15-25 ppt 3 3 3 4 4 4 4 4 4 4 ADULTS >25 ppt 3 3 3 4 4 4 4 4 4 4 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 25 Table 25. Life stages of the Pinfish found within Missippi Sound during each month and under various salinity conditions. Data downEstuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 2 2 2 2 0 0 0 0 0 0 LARVAE 15-25 ppt 3 3 3 2 0 0 0 0 0 0 LARVAE >25 ppt 4 4 3 2 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 2 2 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 26 Table 26. Life stages of the Pink Shrimp found within Missippi Sound during each month and under various salinity conditions. Data 

NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October 

SPAWNING 0-0.5 ppt . 0 0 0 0 . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 2 2 2 2 2 2 0 LARVAE 5-15 ppt 0 0 0 2 3 3 3 3 2 0 LARVAE 15-25 ppt 0 0 0 2 3 3 3 3 2 0 LARVAE >25 ppt 0 0 0 2 3 3 3 3 2 0 JUVENILES 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0.5-5 ppt 3 3 2 2 2 2 2 2 2 2 ADULTS 5-15 ppt 3 3 2 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 4 4 4 3 3 3 3 3 ADULTS >25 ppt 3 3 2 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 27 Table 27. Life stages of the Quahog found within Missippi Sound during each month and under various salinity conditions. Data downEstuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 2 2 2 2 2 2 0 0 SPAWNING 15-25 ppt 0 0 2 3 3 3 3 3 2 0 SPAWNING >25 ppt 0 0 2 3 3 3 3 3 2 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 2 2 2 2 2 2 2 0 LARVAE 15-25 ppt 0 0 2 3 3 3 3 3 2 0 LARVAE >25 ppt 0 0 2 3 3 3 3 3 2 0 JUVENILES 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 JUVENILES 5-15 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 15-25 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES >25 ppt 2 2 2 2 2 2 2 2 2 2 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 2 2 2 2 2 2 2 0 EGGS 15-25 ppt 0 0 2 3 3 3 3 3 2 0 EGGS >25 ppt 0 0 2 3 3 3 3 3 2 0 ADULTS 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 ADULTS 5-15 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 15-25 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS >25 ppt 2 2 2 2 2 2 2 2 2 2 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 28 Table 28. Life stages of the Red Drum found within Missippi Sound during each month and under various salinity conditions. Data doEstuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 2 2 2 0 0 0 0 2 3 3 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 2 2 2 0 0 0 0 2 3 3 LARVAE 15-25 ppt 3 3 2 0 0 0 0 2 4 4 LARVAE >25 ppt 3 3 2 0 0 0 0 2 4 4 JUVENILES 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 2 2 2 0 0 0 0 2 3 3 EGGS >25 ppt 3 3 2 0 0 0 0 2 4 4 ADULTS 0-0.5 ppt 0 0 0 2 2 2 2 2 2 0 ADULTS 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 5-15 ppt 2 2 2 2 2 2 2 2 2 2 ADULTS 15-25 ppt 3 3 2 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Essential Fish Habitat Assessment Impo 29 Table 29. Life stages of the Sand Seatrout found within Missippi Sound during each month and under various salinity conditions. Data NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 2 3 3 3 3 3 3 3 2 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 2 2 2 2 2 2 2 2 2 LARVAE 15-25 ppt 0 2 3 3 3 3 3 3 3 2 LARVAE >25 ppt 0 2 3 3 3 3 3 3 3 2 JUVENILES 0-0.5 ppt 3 3 3 3 4 5 5 5 5 4 JUVENILES 0.5-5 ppt 3 3 3 4 4 5 5 5 5 4 JUVENILES 5-15 ppt 3 3 3 4 4 5 5 5 5 4 JUVENILES 15-25 ppt 3 3 3 4 4 5 5 5 5 4 JUVENILES >25 ppt 3 3 3 4 4 5 5 5 5 4 EGGS 0-0.5 ppt . 0 0 0 . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 2 2 2 2 2 2 2 2 2 EGGS >25 ppt 0 2 3 3 3 3 3 3 3 2 ADULTS 0-0.5 ppt 2 2 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 3 3 4 4 4 4 4 4 4 ADULTS 5-15 ppt 3 3 3 4 4 4 4 4 4 4 ADULTS 15-25 ppt 3 3 3 4 4 4 4 4 4 4 ADULTS >25 ppt 3 3 3 4 4 4 4 4 4 4 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Table 30. Life stages of the Sheepshead found within Missippi Sound during each month and under various salinity conditions. Data do

Estuarine Living Marine Resources Database. 

Life Stage Salinity January February March April May June July August September October NoSPAWNING 0-0.5 ppt . 0 0 0 . . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 2 2 2 2 2 2 2 0 0 0 0 LARVAE 15-25 ppt 2 3 3 3 2 2 2 0 0 0 0 LARVAE >25 ppt 2 3 3 3 2 2 2 0 0 0 0 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Table 31. Life stages of the Sheepshead Minnow found within Missippi Sound during each month and under various salinity conditionsNOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October NoSPAWNING 0-0.5 ppt . 0 0 0 . . . . . . . SPAWNING 0.5-5 ppt 0 0 0 3 3 3 3 3 3 3 0 SPAWNING 5-15 ppt 0 0 0 3 4 4 4 4 4 3 0 SPAWNING 15-25 ppt 0 0 0 3 4 4 4 4 4 3 0 SPAWNING >25 ppt 0 0 0 3 3 3 3 3 3 3 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . . LARVAE 0.5-5 ppt 0 0 0 3 3 3 3 3 3 3 3 LARVAE 5-15 ppt 0 0 0 3 4 4 4 4 4 3 3 LARVAE 15-25 ppt 0 0 0 3 4 4 4 4 4 3 3 LARVAE >25 ppt 0 0 0 3 3 3 3 3 3 3 3 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 3 3 3 3 4 4 4 4 4 4 3 JUVENILES 5-15 ppt 3 3 3 3 4 4 4 4 4 4 3 JUVENILES 15-25 ppt 3 3 3 3 4 4 4 4 4 4 3 JUVENILES >25 ppt 3 3 3 3 4 4 4 4 4 4 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . . EGGS 0.5-5 ppt 0 0 0 3 3 3 3 3 3 3 0 EGGS 5-15 ppt 0 0 0 3 4 4 4 4 4 3 0 EGGS 15-25 ppt 0 0 0 3 4 4 4 4 4 3 0 EGGS >25 ppt 0 0 0 3 3 3 3 3 3 3 0 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Table 32. Life stages of the Silver Perch found within Missippi Sound during each month and under various salinity conditions. Data d

Estuarine Living Marine Resources Database. 

Life Stage Salinity January February March April May June July August September October NoSPAWNING 0-0.5 ppt . 0 0 0 . . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 2 3 3 3 3 3 2 2 0 SPAWNING >25 ppt 0 0 2 3 3 3 3 3 2 2 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 2 3 3 3 3 3 3 2 0 LARVAE 15-25 ppt 0 0 2 3 3 3 3 3 3 2 0 LARVAE >25 ppt 0 0 2 3 3 3 3 3 3 2 0 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 2 3 3 3 3 3 2 2 0 EGGS 15-25 ppt 0 0 2 3 3 3 3 3 2 2 0 EGGS >25 ppt 0 0 2 3 3 3 3 3 2 2 0 ADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Table 33. Life stages of the Silversides found within Missippi Sound during each month and under various salinity conditions. Data doEstuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October NoSPAWNING 0-0.5 ppt . 2 3 3 . . . . . . . SPAWNING 0.5-5 ppt 0 2 3 4 4 4 4 4 3 2 2 SPAWNING 5-15 ppt 0 2 3 4 4 4 4 4 3 2 2 SPAWNING 15-25 ppt 0 2 3 4 4 4 4 4 3 2 2 SPAWNING >25 ppt 0 2 3 3 3 3 3 3 3 2 2 LARVAE 0-0.5 ppt . 2 3 3 . . . . . . . LARVAE 0.5-5 ppt 0 2 3 4 4 4 4 4 3 3 2 LARVAE 5-15 ppt 0 2 3 4 4 4 4 4 3 3 2 LARVAE 15-25 ppt 0 2 3 4 4 4 4 4 3 3 2 LARVAE >25 ppt 0 2 3 3 3 3 3 3 3 3 2 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 4 4 4 4 4 4 4 4 4 4 4 JUVENILES 5-15 ppt 4 4 4 4 4 4 4 4 4 4 4 JUVENILES 15-25 ppt 4 4 4 4 4 4 4 4 4 4 4 JUVENILES >25 ppt 4 4 4 4 4 4 4 4 4 4 4 EGGS 0-0.5 ppt . 2 3 3 . . . . . . . EGGS 0.5-5 ppt 0 2 3 4 4 4 4 4 3 2 2 EGGS 5-15 ppt 0 2 3 4 4 4 4 4 3 2 2 EGGS 15-25 ppt 0 2 3 4 4 4 4 4 3 2 2 EGGS >25 ppt 0 2 3 4 4 4 4 4 3 2 2 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 4 4 4 4 4 4 4 4 4 4 4 ADULTS 5-15 ppt 4 4 4 4 4 4 4 4 4 4 4 ADULTS 15-25 ppt 4 4 4 4 4 4 4 4 4 4 4 ADULTS >25 ppt 4 4 4 4 4 4 4 4 4 4 4 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Table 34. Life stages of the Southern Flounder found within Missippi Sound during each month and under various salinity conditions. DNOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October NoSPAWNING 0-0.5 ppt . 0 0 0 . . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 2 2 2 2 0 0 0 0 2 2 2 LARVAE 15-25 ppt 3 3 3 2 0 0 0 0 2 3 3 LARVAE >25 ppt 3 3 3 2 0 0 0 0 2 3 3 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Table 35. Life stages of the Spanish Mackerel found within Missippi Sound during each month and under various salinity conditions. D

NOAA's Estuarine Living Marine Resources Database. 

Life Stage Salinity January February March April May June July August September October NoSPAWNING 0-0.5 ppt . 0 0 0 . . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE >25 ppt 0 0 0 0 0 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 0 JUVENILES 0.5-5 ppt 0 0 2 2 2 2 2 2 2 2 2 JUVENILES 5-15 ppt 0 0 2 3 3 3 3 3 3 3 2 JUVENILES 15-25 ppt 2 2 2 3 3 3 3 3 3 3 2 JUVENILES >25 ppt 2 2 2 3 3 3 3 3 3 3 2 EGGS 0-0.5 ppt . 0 0 0 . . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 0 ADULTS 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 0 ADULTS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 ADULTS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 ADULTS 15-25 ppt 2 2 2 2 2 3 3 3 2 2 2 ADULTS >25 ppt 2 2 2 3 3 3 3 3 3 2 2 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Table 36. Life stages of the Spot found within Missippi Sound during each month and under various salinity conditions. Data downloadEstuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October NoSPAWNING 0-0.5 ppt . 0 0 0 . . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 3 3 2 2 0 0 0 0 0 2 3 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 2 2 2 2 0 0 0 0 0 2 2 LARVAE 15-25 ppt 4 4 3 2 0 0 0 0 0 2 3 LARVAE >25 ppt 4 4 3 2 0 0 0 0 0 2 3 JUVENILES 0-0.5 ppt 4 4 4 4 4 4 4 4 4 4 4 JUVENILES 0.5-5 ppt 5 5 5 5 5 5 5 5 5 5 5 JUVENILES 5-15 ppt 5 5 5 5 5 5 5 5 5 5 5 JUVENILES 15-25 ppt 5 5 5 5 5 5 5 5 5 5 5 JUVENILES >25 ppt 5 5 5 5 5 5 5 5 5 5 5 EGGS 0-0.5 ppt . 0 0 0 . . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 3 3 2 2 0 0 0 0 0 2 2 ADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 2 2 2 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 2 2 2 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 2 2 2 3 3 3 3 3 3 3 3 ADULTS >25 ppt 2 2 2 3 3 3 3 3 3 3 3 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Table 37. Life stages of the Spottede Seatrout found within Missippi Sound during each month and under various salinity conditions. DNOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October NoADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . . EGGS 0.5-5 ppt 0 0 0 2 2 2 2 2 0 0 0 EGGS 5-15 ppt 0 0 2 3 3 3 3 3 2 0 0 EGGS 15-25 ppt 0 2 3 4 4 4 4 4 3 2 0 EGGS >25 ppt 0 2 3 4 4 4 4 4 3 2 0 JUVENILES 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 5-15 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 15-25 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES >25 ppt 3 3 3 3 3 3 3 3 3 3 3 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . . LARVAE 0.5-5 ppt 0 0 0 2 2 2 2 2 0 0 0 LARVAE 5-15 ppt 0 0 2 3 3 3 3 3 2 0 0 LARVAE 15-25 ppt 0 2 3 4 4 4 4 4 3 2 0 LARVAE >25 ppt 0 2 3 4 4 4 4 4 3 2 0 SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . . SPAWNING 0.5-5 ppt 0 0 0 2 2 2 2 2 0 0 0 SPAWNING 5-15 ppt 0 0 2 3 3 3 3 3 2 0 0 SPAWNING 15-25 ppt 0 2 3 4 4 4 4 4 3 2 0 SPAWNING >25 ppt 0 2 3 4 4 4 4 4 3 2 0 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Table 38. Life stages of the Striped Mullet found within Missippi Sound during each month and under various salinity conditions. Data NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October NoADULTS 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 0.5-5 ppt 3 3 3 4 4 4 4 4 4 4 3 ADULTS 5-15 ppt 3 3 3 4 4 4 4 4 4 4 3 ADULTS 15-25 ppt 3 3 3 4 4 4 4 4 4 4 3 ADULTS >25 ppt 3 3 3 4 4 4 4 4 4 4 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 3 3 3 3 3 3 3 3 3 3 3 JUVENILES 0.5-5 ppt 5 5 4 4 5 5 5 5 5 4 4 JUVENILES 5-15 ppt 5 5 4 4 5 5 5 5 5 4 4 JUVENILES 15-25 ppt 5 5 4 4 5 5 5 5 5 4 4 JUVENILES >25 ppt 5 5 4 4 5 5 5 5 5 4 4 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 2 2 2 2 0 0 0 0 0 0 0 LARVAE 15-25 ppt 3 3 3 3 2 0 0 0 0 2 2 LARVAE >25 ppt 4 4 4 3 2 0 0 0 0 2 2 SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 0 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Table 39. Life stages of the Tarpon found within Missippi Sound during each month and under various salinity conditions. Data downlEstuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October NoADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 2 ADULTS 5-15 ppt 2 2 2 2 2 2 2 2 2 2 2 ADULTS 15-25 ppt 2 2 2 2 2 2 2 2 2 2 2 ADULTS >25 ppt 2 2 2 2 2 2 2 2 2 2 2 EGGS 0-0.5 ppt . 0 0 0 . . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 0 0 0 0 0 0 0 0 JUVENILES 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 2 JUVENILES 0.5-5 ppt 2 2 2 2 2 2 2 2 2 2 2 JUVENILES 5-15 ppt 2 2 2 2 2 2 2 2 2 2 2 JUVENILES 15-25 ppt 2 2 2 2 2 2 2 2 2 2 2 JUVENILES >25 ppt 2 2 2 2 2 2 2 2 2 2 2 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 15-25 ppt 0 0 0 0 0 2 2 2 2 2 2 LARVAE >25 ppt 0 0 0 0 2 3 3 3 3 3 3 SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 0 0 0 0 0 0 0 0 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

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Appendix 3–A–A Casotte La

Essential Fish Habitat Assessment Impo 40 

Table 40. Life stages of the White Shrimp found within Missippi Sound during each month and under various salinity conditions. Data NOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October NoADULTS 0-0.5 ppt 2 2 2 2 2 2 2 2 2 2 2 ADULTS 0.5-5 ppt 2 2 2 2 2 3 3 3 2 2 2 ADULTS 5-15 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS 15-25 ppt 3 3 3 3 3 3 3 3 3 3 3 ADULTS >25 ppt 3 3 3 3 3 3 3 3 3 3 3 EGGS 0-0.5 ppt . 0 0 0 . . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS >25 ppt 0 0 0 2 2 2 2 2 2 2 2 JUVENILES 0-0.5 ppt 2 2 2 2 2 3 3 3 2 2 2 JUVENILES 0.5-5 ppt 3 3 3 3 3 4 4 4 4 4 4 JUVENILES 5-15 ppt 3 3 3 3 3 4 4 4 4 4 4 JUVENILES 15-25 ppt 3 3 3 3 3 4 4 4 4 4 4 JUVENILES >25 ppt 3 3 3 3 3 4 4 4 4 4 4 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . . LARVAE 0.5-5 ppt 0 0 0 2 3 4 4 3 4 4 3 LARVAE 5-15 ppt 0 0 0 2 3 4 4 3 4 4 3 LARVAE 15-25 ppt 0 0 0 2 3 4 4 3 4 4 3 LARVAE >25 ppt 0 0 0 2 3 4 4 3 4 4 3 SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING >25 ppt 0 0 0 2 2 2 2 2 2 2 2 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Appendix 3–A–A Casotte La

Essential Fish Habitat Assessment Impo 41 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Appendix 3–A–A Casotte La

Essential Fish Habitat Assessment Impo 42 

Table 41. Life stages of the Yellowfin Menhaden found within Missippi Sound during each month and under various salinity conditionsNOAA's Estuarine Living Marine Resources Database. Life Stage Salinity January February March April May June July August September October NoADULTS 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 0 ADULTS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 ADULTS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 ADULTS 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 ADULTS >25 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 0-0.5 ppt . 0 0 0 . . . . . . . EGGS 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 EGGS 15-25 ppt 2 2 2 0 0 0 0 0 0 0 2 EGGS >25 ppt 2 2 2 0 0 0 0 0 0 0 2 JUVENILES 0-0.5 ppt 0 0 0 0 0 0 0 0 0 0 0 JUVENILES 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 JUVENILES 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 JUVENILES 15-25 ppt 0 0 0 0 0 0 0 0 0 0 0 JUVENILES >25 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 0-0.5 ppt . 0 0 0 . . . . . . . LARVAE 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 LARVAE 15-25 ppt 2 2 2 0 0 0 0 0 0 0 2 LARVAE >25 ppt 2 2 2 0 0 0 0 0 0 0 2 SPAWNING 0-0.5 ppt . 0 0 0 . . . . . . . SPAWNING 0.5-5 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 5-15 ppt 0 0 0 0 0 0 0 0 0 0 0 SPAWNING 15-25 ppt 2 2 2 0 0 0 0 0 0 0 2 SPAWNING >25 ppt 2 2 2 0 0 0 0 0 0 0 2 0=not present, 2=rare, 3=common, 4=abundant, 5=highly abundant, and .=no data 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Appendix 3–A Casotte Landing Natural Gas 

Essential Fish Habitat Assessment Import Terminal Project 

32 September 2005 

Appendix 3–A–B 

NMFS Seasonal and Year-round EFH 

(Source: http://galveston.ssp.nmfs.gov/research/fisheryecology/EFH/Relative/estuaries/) 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico

TX

FL

AL GA

LA

AR

MS

OK NC

SC

TN

Map Location

Bayou Casotte

Energy, LLC

Legend

Project Location

μ

Casotte Landing

Natural Gas Import Terminal Project

April 2005 Project #: 01231-021 X:\Projects\ChevronTexaco\CTGG-Pascagoula\MXD\EFH figures\brown_shrimp_adults-1.mxd

EFH Mapping - Adult Brown Shrimp

Image Source: NOAA-NMFS Galveston

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Mississippi Sound, MS White Shrimp, Penaeus setiferus Juveniles

EFH Mapping, NMFS Galveston Lab http://galveston.ssp.nmfs.gov/efh July, 1998

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Mississippi Sound, MS White Shrimp, Penaeus setiferus Adults

EFH Mapping, NMFS Galveston Lab http://galveston.ssp.nmfs.gov/efh July, 1998

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Red grouper, Epinephelus morio Juveniles

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Spawning area (April-May)

-Nursery area (Year-round)

EEZ

Spawning area shown is one of several in the Gulf, but is the only one that has been

positively identified.

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Red grouper, Epinephelus morio Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult area (Year-round)

-Adult occurrence

EEZ

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Gag, Mycteroperca microlepis Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult occurrence

EEZ

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Gag, Mycteroperca microlepis Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult occurrence

EEZ

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Scamp, Mycteroperca phenax Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult occurrence

EEZ

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Scamp, Mycteroperca phenax Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult occurrence

EEZ

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Red snapper, Lutjanus campechanus Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Major Adult area (Year-round)

-Adult area (Year-round)

EEZ

Spawning, from June to October, occurs throughout the adult areas.

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Tilefish, Lopholatilus chamaeleonticeps Juveniles

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Spawning and nursery area

EEZ

Spawning occurs throughout the adult area from March to September. The

adult area is also the year-round nursery area.

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Tilefish, Lopholatilus chamaeleonticeps Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

- Adult area (Year-round)

EEZ

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Yellowtail snapper, Ocyurus chrysurus Juveniles

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Spawning area (Spring and Summer)

-Nursery area

EEZ

Spawning occurs predominantly in Spring and Summer in adult areas in the

eastern Gulf.

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Yellowtail snapper, Ocyurus chrysurus Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Major Adult area (Year-round)

-Adult area (Year-round)

EEZ

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Greater amberjack, Seriola dumerili Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult area (Year-round)

EEZ

Year-round spawning occurs throughout the adult area. Year-round nursery

area is throughout the adult area.

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Greater amberjack, Seriola dumerili Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult area (Year-round)

EEZ

Year-round spawning occurs throughout the adult area. Year-round nursery

area is throughout the adult area.

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Mississippi Sound, MS Gulf Stone Crab, Menippe adina Juveniles

EFH Mapping, NMFS Galveston Lab http://galveston.ssp.nmfs.gov/efh July, 1998

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Mississippi Sound, MS Gulf Stone Crab, Menippe adina Adults

EFH Mapping, NMFS Galveston Lab http://galveston.ssp.nmfs.gov/efh July, 1998

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Mississippi Sound, MS Stone Crab, Menippe mercenaria Adults

EFH Mapping, NMFS Galveston Lab http://galveston.ssp.nmfs.gov/efh July, 1998

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. King mackerel, Scomberomorus cavalla Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult area (Year-round)

EEZ

Adults area is also spawning area from May to November, and is year-round

nursery area.

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. King mackerel, Scomberomorus cavalla Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult area (Year-round)

EEZ

Adults area is also spawning area from May to November, and is year-round

nursery area.

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Mississippi Sound, MS Spanish Mackerel, Scomberomorus maculatus Juveniles

EFH Mapping, NMFS Galveston Lab http://galveston.ssp.nmfs.gov/efh July, 1998

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Mississippi Sound, MS Spanish Mackerel, Scomberomorus maculatus Adults

EFH Mapping, NMFS Galveston Lab http://galveston.ssp.nmfs.gov/efh July, 1998

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Cobia, Rachycentron canadum Juveniles

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Nursery area (Year-round)

EEZ

See additional EFH information at: http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Seasonality in the nursery area is the same as in the adult areas. In the

northern Gulf, spawning (Spring, Summer) occurs throughout the adult area,

except in bays and estuaries. Spawning seasonality in the southern Gulf is

unknown.

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Cobia, Rachycentron canadum Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult area (Spring, Summer, and Fall)

-Major Adult area (Winter) and Adult

area (Year-round)

-Adult area (Summer)

EEZ

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

Adults are known to occur year-round throughout the Gulf. In the northern Gulf,

spawning (Spring, Summer) occurs throughout the adult area, except in bays

and estuaries. Spawning seasonality in the southern Gulf is unknown.

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Dolphin, Coryphaena hippurus Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult area (Year-round)

-Adult area (Summer)

EEZ

Spawning and nursery areas occur year-round throughout the adult areas.

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

EEZ

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Gulf of Mexico, U.S. Dolphin, Coryphaena hippurus Adults

Prepared for the GMFMC by the NMFS Fisheries Ecology Branch and the NOS-SEA Division based on species' distributions in the Gulf of Mexico Data Atlas (NOS-OAD-SAB, 1985).

-Adult area (Year-round)

-Adult area (Summer)

EEZ

Spawning and nursery areas occur year-round throughout the adult areas.

See additional EFH information at:

 http://galveston.ssp.nmfs.gov/efh and http://christensenmac.nos.noaa.gov/GOM-EFH

EEZ

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX G 

BAYOU CASOTTE ENERGY 

LETTER OF INTENT AND THE U.S. COAST GUARD WATERWAY 

SUITABILITY REPORT LETTERS

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Jnofflclal FERC-Generated PDF of 20060418-0188 Received by FERC OSEC 04/05/2006 in Docket#: CP05-420-000 

U.S. I)epartment of 

Homeland Security 

United Stttu 

Coast Guard 

Commande¢ 

8ou~ Broad ~ 

MOb4~, AL 36615-13g0 

St~ Sy~x~ spw 

Phone: (251) 441-~40 

FAX: (251) 441-a169 

April 1, 2006 

Mr. Van Button 

Office of Energy Projects 

Fcdvral Energy Regulatory Commission 

888 First Street NE 

Washington, DC 20426 

ORIBINAL 

Dear Mr. Button: 

On March 15, 2006 1 completed a review of the attached Waterway Security Assessment 

(WSA) for tim CasoRe Landing Energy, LLC submitted on February 13, 2006. You arc 

reminded that the attached WSA shall be handled in accordance with the guidelines for 

Sensitive Security Information (SSI). Based upon the review and consultations with the 

Area Maritime Security CommiRe¢, I have determined that the Pascagoula Bar, Horn 

Island Pass, Lower Pascagoula and Bayou CasoRe Channels are suitable for the LNG 

marine tra_~c associated with the project. These waterways can accommodate the 

proposed traffic and thcr¢ is sufficivnt capability within the port community to responsibly 

manage the safety and security risks of this project. 

If you have questions please contact Lieutenant Junior C_n'ade Jonathan Mangum, Waterway 

Management Brunch Chief at (25 !) 441-5940. 

I Enclosure 

Sincerely, , 

. e~: 

Captmn ofthe Port x~ t ,0 ~ 

Commander, Coast Guard Se~--~Mobihh _~ :~_ 

.< ¢..d, -'~ 3~ .b'-- 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Unofficial FERC-Generated PDF of 20061013-0052 Received by FERC OSEC 09/05/2006 in Docket#- CP05-420-000~ 

U.S. Department of 

Homeland Secu r," 

United States 

Coast Guard 

Commander 

U.S. Coast Guard Sector Mobile 

Brookley Complex 

South Broad Street 

Mobile, AL 36615-1390 

Staff Symbol: spw 

Phone: (251 ) 441-5940 

September 5, 2006 

Mr. Van Button - 

Office of Energy Projects 

Federal Energy Regulatory Commission 

888 First Street NE 

Washington, DC 20426 

Dear Mr. Button: OR/G/N4t .... 

I wish to clarify my letter dated April 1, 2006 regarding Casotte Landing Energy, LLC. 

My intention was to give a preliminary evaluation to meet the recommendations of NVIC 

05-05. My evaluation is not final until the United States Coast Guard's required National 

Environmental Policy Act review has been completed. Moreover, any final determination 

of suitability is contingent upon an evaluation of certain conditions which may include: 

a. The establishment of a moving safety zone during LNG vessels' transit of the 

waterway, including the requirements for daylight transit and for one way LNG vessel 

traffic on the waterway, and for another safety / security zone around the LNG facility 

when the LNG vessels are moored. 

b. The submission by the applicant of an annual review of its Waterway Suitability 

Assessment to evaluate if any conditions in the waterway have changed that would require 

issuance of a new Letter of Recommendation (LOR). 

c. The requirement that LNG vessels must navigate the waterway from the Hom 

Island Pass sea buoy (LLNR 320) to the berthing areas with Pascagoula Pilots onboard and 

that tug assistance be provided as deemed necessary by the Pascagoula Pilots. 

d. The requirement that prior to crossing the Gulf Intracoastal Waterway, all LNG 

traffic will be required to make a SECURITE broadcast. 

Plan. 

e. Implementation of a Coast Guard approved LNG Vessel Transit Management 

f. Availability of Coast Guard resources to implement appropriate security 

measures. 

If you have questions please contact Lieutenant Jonathan Mangum, Waterway 

Management Branch Chief, at (251) 441-5940. 

Sincerely, 

E.M. STANTON 

Captain, U. S. Coast Guard 

Altemate Captain of the Port 

Deputy Commander, Sector Mobile 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX H 

COMMENTS ON THE DRAFT EIS AND RESPONSES

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-1

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-2

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-3

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-4

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-5

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-6

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-7

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-8

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-9

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-10

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-11

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-12

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

H-13

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

PM1-1 PM1-2 PM1-3 PM1-4 

As discussed in section 2.Energy, LLC (Bayou Casotte intermediate fluid vaporizer liquefied natural gas (LNG). to the heating provided by the system, two natural gas fire supplement or replace a portiprovided by the heat exchange 

PM1-1 

PM1-2 

Impacts on wetlands assocCasotte Landing Project and Bproposed mitigation measures in Section 4.4. Bayou Casotte Energy would long spur that would contain existing interstate naturWaterbodies and wetlands affpipeline are described in serespectively. 

PM1-3 

Impacts on recreational associated with the Bayou Care discussed in Sections 4.7.

PM1-4 

H-14

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

PM1-5 

PM1-4 

PM1-5 

Thank you for your commeprovides information on the mfuture hurricane surge events. 

H-15

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

PM1-5 

H-16

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

PM1-6 

PM1-5 

PM1-6 As discussed in Section 2.9

Project is set to be between 25 

H-17

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

PM1-7 PM1-8 PM1-9 PM1-10 

PM1-6 

PM1-7 

Mitigation measures Bayou implement to minimize impadescribed in sections 4.4.4 anin section 4.4.5, we have recCasotte Energy continue to cCorps of Engineers (COE); MiMarine Resources (MDMRServices (FWS); and other finalize its Mitigation Plan. 

PM1-8 

The dispersion modeling was time the Draft EIS was pubmodeling was completed foperiod and is discussed in SecEIS. 

PM1-9 

The factors used in the dehurricane levee around thdescribed in Section 4.1.3.4.

PM1-10 

Sediment-related issues aproposed project are discusse

H-18

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

PM1-11 PM1-12 

PM1-10 

PM1-11 

Section 4.1.3.1 discusses the project area. The risk of a occurring in the project area is 

PM1-12 

Flooding and storm-related ithe proposed project are 4.1.3.5.

H-19

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

PM1-13 PM1-14 PM1-15 

PM1-13 

Impacts on wetlands, fisherieresult of the proposed projSection 4.4, 4.5.2, and 4.11.1, 

PM1-14 

Impacts on air quality as a project and Bayou Casottmitigation measures are descr4.11.1.

PM1-15 

The primary source for LNclosed loop IFV system. Bayalso proposed two natural gaas a back-up. Table 4.11.1stationary and mobile soursource labeled “heaters” prinformation for the two natuheaters described in the comm

H-20

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

PM1-16 PM1-17 PM1-18 PM1-19 PM1-20 

PM1-15 

PM1-16 

This comment is specific to Project; Docket Number CP06

PM1-17 

Both methods for vaporizatioin Section 2.1.1.3. 

PM1-18 

This comment is specific to Project; Docket Number CP06

PM1-19 

The purpose and need for Landing LNG Project is dSection 1.1. 

PM1-20 

The purpose and need for Landing LNG Project is discu1.1. Alternatives to the proalternative locations for the 

analyzed in Section 3.0.

H-21

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Public Meeting 

PM1-21 

PM1-20 

PM1-21 

Offshore LNG terminals walternative to the proposed prodescribed in section 3.3.2, environmentally preferable alternatives to the Casotte Lan

H-22

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PM1-22 PM1-23 PM1-24 

PM1-22 

As discussed in section 4.12.1 explosive as it is normally trLNG vapors can explode confined space and ignited. While giving recognition to regarding public safety, we radiation and flammable vaevaluated in section 4.12 of tbe confined to the site, land tby Bayou Casotte Energy, waters. Also, the thermal raLNG spills on water from tbreach scenarios, as evaluateEIS, would be less than 1 mile As stated in the EIS, the entiGulf of Mexico through the Island Pass, Lower PascagouChannels to the LNG berth, hcommunities adjacent to the transient hazard area. Thexcluded uses within the eximport terminal, and that whiwith the LNG vessel transeliminated, they can be manag

PM1-23 

Measures that would be imminimize impacts on marine min detail in Section 4.6.1. 

PM1-24 

The purpose and need for Landing LNG Project are dsection 1.1. Section 4.8.2 pthe impacts the proposed proeconomy and employment in t

PM1-25 

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PM1-25 PM1-26 PM1-27 

PM1-25 

See response to PM1-22. Regarding pipeline safety, Transportation’s Office of responsible for regulating coCFR Part 192 of the FeRegulations regarding tmaintenance of natural gas pipthe state agency participatinpipeline safety program. Pipein Section 4.12.7. 

PM1-26 The environmental impacts 

Casotte Landing LNG Projeanalyzed in Sections 4.3.1.4.11.1.4 of the EIS. All of thparticipated as cooperatindevelopment of this EIS. 

PM1-27 

Impacts on air quality as a project and Bayou Casottmitigation measures are descr4.11.1. 

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PM1-28 PM1-29 

PM1-27 

PM1-28 

This comment is specific to Project and will be addressed project; Docket Number CP06

PM1-29 

Bayou Casotte Energy would the proposed facilities in applicable permits. The maand consultations required fLanding Project are identified 

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PM1-30 

PM1-30 

Comment noted. All commenEIS for the proposed project hand are included in this comm

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Federal Agency 

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F1-1 F1-2 F1-3 F1-4F1-5 F1-6 

F1-1 

F1-2 

F1-3 

F1-4

F1-5 

F1-6 

Thank you for your comment. 

Bayou Casotte Energy’s Field dredged material did not idioxins/furans (see Table A-3). Plan was submitted to the COE aprior to sampling efforts being Casotte Energy. Section 4.2.2 of the DEIS conditicomplete all sediment sampconsultation and submit a report tcooperating agencies prior to issuThat information was filed with Fin the Final EIS. 

Section 4.2.1.5 discusses erosioerosion is not specifically mentionto be a problem because of the larea. Bayou Casotte Energy’s SProcedures (as modified) addresprovides guidelines for erosion co

Section 4.13.4.2 addresses cumuFERC concludes that with mitiganet increase in the regional coSection 4.4.3 defines brackish esection 4.4.4.2 discusses impacwetlands.

As described in Section 3.4, one of the LNG terminal is the minimizimpact from construction and opof most higher quality wetlands. 

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F1-7 F1-8 F1-9 F1-10 F1-11 F1-12 

F1-7 

F1-8F1-9

F1-10F1-10

F1-11

F1-12

Bayou Casotte Energy is developin collaboration with the FWS, COwould address the appropriate miFWS is involved in the developmeplan, this comment should be addparticipation. The final mitigation approved by the cooperating agenthe FERC prior to construction. Fwill begin until the COE has issuepermits. 

Comment noted. The FWS should review of the Section 404 and 401 

Section 4.6.2.3 discusses how conto avoid migratory birds. Clearing would occur during the first quarteMarch 31) and would avoid the pe(April 1 – June 30).

We have included a condition that consult with the Grand Bay Preseconstruction. 

The DEIS acknowledges the loss during dredging in Section 4.5.2.2

We have included a condition that Energy continue to consult with Nproject construction to address anagency may have. 

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F1-13 F1-14 

F1-12 

F1-13F1-14

Bayou Casotte Energy has compthese species and their habitats. that the proposed Project would these species or their habitat and have no records of these species proposed Project area. The FERcondition that Bayou Casotte Enesurvey immediately prior to constFWS.

Construction would not affect LNoperation of the proposed Projecthat LNG carriers would use durinexisting, actively used shipping csignificantly increased effects to HIslands are anticipated. The EIS impacts to resources on the islanaccidental and intentional releaseLNG carriers as they pass Horn IIsland. 

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F2-1F2-2 F2-3 F2-4 F2-5 F2-6 

F2-2 

F2-3 F2-5 

F2-4F2-6

As discussed in Section 4.4.5 of tEnergy prepared a wetland coordination with several agencplan was included in its Joisubmitted to the COE on July 27, 

Since the crude oil berth is simply not new, crude oil tanker offloadinImpacts from cooling and ballast early stages of aquatic life bdiscussed in Sections 4.3.2.2 an(Section 4.5.2.2) conditioned Baycomplete consultations with regarding these impacts and the discussion of those consultations. 

F2-1

Impacts on water quality and fisslip are discussed in Sections 4.5.2.2. NOAA Fisheries is alconsultations regarding develoconstruction and maintenance drwater quality monitoring (see 4.3.2.2). We have included NOArequired in the condition (Secti

impacts and potential mitigmeasures. 

We have included a condition Energy consult with all of the nregards to potential effects on wat

Dredging disposal alternativesrestoration, are already discussed 

Beneficial use disposal is discusIn Section 4.2.2 we included a Bayou Casotte Energy to consult 

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F2-6 

F2-6 continued 

including NOAA regarding saevaluation of the suitability of options under considerationsites. The Final EIS has beresults of the sampling and eof disposal placement. 

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F3-1 Thank you for your review of the D

F3-1 

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F4-1 F4-2F4-3 F4-4 

F4-1 

Section 4.11.1-2 has been evisibility and deposition targets. 

F4-2 

Table 4.11.1-1 footnote “f” giconsidered, 2002 – 2004. characteristics will be added to t

F4-3 

Table 4.11.1-4 does show tugboemissions. The sub-category will be changed to bold typefacitems that follow are mobile sourBayou Casotte Energy conductedetermined the Proposed ProjPSD source, as discussed in Se

F4-4 

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F4-5 F4-6 F4-7F4-8 F4-9 F4-10 F4-11

Bayou Casotte Energy conductedetermined the Proposed Project source, as discussed in Section 4Bayou Casotte Energy conductefiled the data with the Secretary are included in the public recordincluded in Section 4.11.1.4 of the 

Bayou Casotte Energy conductethe DEIS was prepared. The Secretary and included with th4.11.1.4 and 4.13.9 of the FEIS information. 

Bayou Casotte Energy conductethe DEIS was prepared. The Secretary and included with the pof the FEIS includes our review analysis filed by Bayou Casotte E

The Casotte Landing LNG Faciliavailable from the Chevron requirements will be provided Landing LNG Facility. The Chevits operations to provide heat tFacility and there will be no eRefinery that are associated witFacility. The operation of crude oil tankeCasotte Landing LNG Facility. being relocated to make room fcrude oil tanker operations are Refinery, not with the Casotte Launloaded from tankers will not be used in association with the CasoPage 4-92 will be corrected to ref

F4-5 

F4-8 

F4-9 

F4-10 F4-11 

F4-6 

F4-7 

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F4-12 F4-13 

F4-12 Bayou Casotte Energy conduc

after the DEIS was prepared. Tthe Secretary and included witresults of this analysis was revthe conclusions in Section 5.0 review and analysis. 

F4-13 Bayou Casotte Energy filed its 

with the COE on July 28, 2006COE is ongoing. An analysis odredged material disposal plan EIS in Section 4.2.2.

F4-14 

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F4-14 F4-15 F4-16

F4-14 

As stated in Section 4.8.8 of thsocioeconomic information haanalyzed regarding EnvironmenLNG terminal is located in an development; and based on the minority or low-income group is the burden of the proposed Proje

F4-15 

The thermal radiation level of Executive Summary has been cfeet to 2,164-5,220 feet. 

F4-16 

Analyses regarding the estimassociated un-ignited vapor clometer-diameter hole have been 

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F4-17 

F4-17 

FERC staff’s conclusion that thaccidental causes should be conon several factors. As discu“Hazards,” the December 2004 Saccidental events found that gcollisions could result in minor shspill; while high speed collisions ccargo tank breach. It is anticipawould be met by tugs in the vicBayou Casotte and Upper Pascwith lines and utilized to assisberthing the ship. Ship speeds range between 3 and 10 knotsimposed by the Coast Guard and tugs to assist the LNG ship wopossibility of a cargo containmeLNG spill from an accidental collHowever, FERC staff perfocalculations based on a 1-metebreach. Results of this analysis vapor would extend to the ma

event to create the hole in the LNouter hull, the inner hull, and cwithout ignition. It is also unlike

cloud could achieve its maxisurfaces without encountering an to imply that flammable vapor maximum distance, but it would bevent creating a hole would aignition sources which would leasubsequent thermal radiation distances to range from 2,164 tradiation level of 1,600 Btu/ft2residences within the 1,600 Btu/ft

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F4-18 F4-19 F4-20

See F4-17We have recommended that aCommission include a conditioshould include a HAZOP review and that a copy of the rerecommendations should be fthe Commission. If the projCasotte Energy would be reqcondition, among others, prapproving construction of the involve FERC staff’s review oBayou Casotte Energy to ensuresponse to FA4-20.

The HAZOP/MOC process is aused to thoroughly review subsequent changes to ensusafely operate within the estabAs part of the Commiscompliance program we have Commission authorization requto file monthly reports during semi-annual operational reporeports identify changes in the foperating conditions, abnormaplant activity, and planned plstaff would review these reporstaff’s construction and annuoperations inspections at the would review Bayou Casotte program and any recommendat

F4-18 

F4-19 

F4-20 

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F4-21 

F4-22 F4-22 

Information regarding the geoghorizon used in the cumulativprovided in the introductory parageographic boundaries and tqualitative because they vary dbeing considered. In general, Pascagoula area and 20 years However, as indicated in secproposals to evaluate, the impaare not reasonably foreseeable. cumulative impacts analysis, we relevant to the resources of concLNG Project. These included maintenance dredging activities, LNG Clean Energy Project aPascagoula Refinery expansion p

Bayou Casotte Energy filed its Jthe FERC and COE on July 28, contained an Addended Wetlanaddressed Bayou Casotte Enerunavoidable wetland losses assProject. The mitigation plan is aSection 4.4.5. 

F4-21 

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G1-1 G1-2 G1-3 G1-4 

As discussed in section 2.1.1.3, BLLC (Bayou Casotte Energy) woufluid vaporizer (IFV) to vaporize th(LNG). As a potential back-up tby the refinery cooling water systeprocess heaters would supplemeof the heat normally provided bsystem. 

Impacts on wetlands associated wLanding Project and Bayou Casomitigation measures are describe4.4. 

Bayou Casotte Energy would conspur that would contain five inteinterstate natural gas pipelines. wetlands affected by the prodescribed in sections 4.3.2 and 4.4

Impacts on recreational boating awith the Bayou Casotte Landing in sections 4.7.3.4 and 4.9.1. 

G1-1 

G1-2 

G1-3 

G1-4 

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G2-1 G2-2 G2-3

G2-1 G2-2

G2-3 

G2-4 

As described in Section 3.4, one the LNG terminal is the minimizimpact from construction and opproposed project has been dimpacts as much as possible. proposes to limit impacts to vegesiting the LNG terminal in aindustrial site and overlappinnonjurisdictional linear facilities way through primarily (Section 4.4.4). 

As described in Section 3.4, one the LNG terminal is the minimizimpact from construction and opproposed project has been dimpacts as much as possible. Tgiven the avoidance, minimizmeasures proposed for this Pwetland impacts would not occur.

Section 4.13.4.2 addresses cumuFERC concludes that with mitiganet increase in the regional coSection 4.4.3 defines brackish esection 4.4.4.2 discusses impawetlands. 

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G2-4 G2-5 G2-6 G2-7 G2-8 

G2-4 

G2-5 G2-6 

G2-7

G2-8 

The DEIS does address wetland Compensatory mitigation is apermitted by the COE in regard to 

As stated in Section 4.4.5, Bayconsidering purchasing mitigatiPoint Mitigation Bank, Old Fort and Round Island, Greenwood Irestoration projects. Generamitigate for the same type of disturbed. The Moss Point MitigaBayou Mitigation Bank are bproposed Project in Jackson Cou

As described in Section 3.4, one the LNG terminal is the minimother environmental impact foperation (p. 3-16). The propodesigned to minimize wetland possible (Section 4.4.4.2). Bproposes to limit impacts to vegesiting the LNG terminal in industrial site and overlappinnonjurisdictional linear facilities way through primarily industrializ

As discussed in Section 4.4.5, Bdeveloping a mitigation plan in FWS, COE, and MDMR, which to construction. The COE wetlallows for public comment pricomment period should be the apublic to comment on the mitigati

The FERC has carefully conimpacts and feels that the minimimpacts, developed in consultstate agencies, is adequate. 

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APPENDIX I 

REFERENCES 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX I 

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REFERENCES 

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U.S. Army Corps of Engineers. 2002b. Long-Term Comprehensive Master Plan for Beneficial Uses of 

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Large-Scale Development in Coastal Mississippi. 

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Available online at http://www.mvd.usace.army.mil/hurricane/chr.php; accessed April 2006. 

U.S. Census Bureau. 2005a. American Fact Finder. Available online at 

http://factfinder.census.gov/servlet/QTGeoSearchByListServlet?ds_name=DEC_2000_SF1_U&_

lang=en&_ts=145972786312; accessed January 2006. 

U.S. Census Bureau. 2005b. Federal, State & Local Governments 1997 State & Local Governments 

County Area Finance & Employment Fastfacts. Available online at 

http://harvester.census.gov/finance/asp/finance.asp; accessed January 2006. 

U.S. Environmental Protection Agency and U.S. Army Corps of Engineers. 1991. Evaluation of 

Dredged Material Proposed for Ocean Disposal – Testing Manual. EPA-503/8-91/001. 

U.S. Environmental Protection Agency and U.S. Army Corps of Engineers. 1998. Evaluation of 

Dredged Material Proposed for Discharge in Waters of the U.S. – Testing Manual. EPA-823-B98-004. Washington, D.C. 

U.S. Environmental Protection Agency. 1974. Community Noise, NTID 300.3. Information on Levels of 

Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety, 

Washington, DC. 

U.S. Environmental Protection Agency. 1991. Final Environmental Impact Statement for the 

Designation of an Ocean Dredged Material Disposal Site Located Offshore Pascagoula, 

Mississippi. Region IV, Atlanta, Georgia. 

U.S. Environmental Protection Agency. 1993. Regional Implementation Manual, Requirements and 

Procedures for Evaluation of the Ocean Disposal of Dredged Material in Southeastern Atlantic 

and Gulf Coastal Waters. Region IV, Atlanta, Georgia. 

U.S. Environmental Protection Agency. 1993. Method for Assessing the Chronic Toxicity of Marine and 

Estuarine Sediment-associated Contaminants with the Amphipod Leptocheirus plumulosus-First 

Edition. March 2001. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX I 

REFERENCES

I-6

U.S. Fish and Wildlife Service. 2003. Final Rule, Designation of Critical Habitat for the Gulf Sturgeon, 

U.S. Fish and Wildlife Service, Washington, D.C. 

U.S. Fish and Wildlife Service. 2006a. Bald Eagle: Life History, U.S. Fish and Wildlife Service. 

Available online at http://ecos.fws.gov/docs/life_histories/B008.html; accessed March 2006. 

U.S. Fish and Wildlife Service. 2006b. Draft National Bald Eagle Management Guidelines, U.S. Fish 

and Wildlife Service. Available online at http://www.fws.gov/migratorybirds/issues/

BaldEagle/Mgmt.Guidelines.2006.pdf; accessed March 2006. 

U.S. Fish and Wildlife Service. 2006c. Brown Pelican: Life history, U.S. Fish and Wildlife Service. 

Available online at http://ecos.fws.gov/docs/life_histories/B02L.html; accessed March 2006. 

U.S. Fish and Wildlife Service. 2006d. Threatened and Endangered Species in the Southeast, U.S. Fish 

and Wildlife Service. Available online at http://www.fws.gov/southeast/es/T&E%20Species.htm; 

accessed January 2006.

U.S. Fish and Wildlife Service. 2006e. West Indian manatees stock assessments, U.S. Fish and Wildlife 

Service, Jacksonville, Florida. Available online at 

http://www.nmfs.noaa.gov/pr/PR2/Stock_Assessment_Program/FWS/West_Indian_Manatee_(Fl

orida)/westindianmanatee_florida.pdf; accessed January 26, 2006. 

U.S. Geological Survey. 2002. National Seismic Hazard Maps, Central and Eastern U.S. Available 

online at http://earthquake.usgs.gov/research/hazmaps/products_data/2002/ceus2002.php; 

accessed April 2006. 

U.S. Geological Survey. 2004. USGS Earthquake Hazards Program, National Seismic Hazard Mapping 

Project, FAQ. Available online at 

http://earthquake.usgs.gov/research/hazmaps/haz101/faq/faq.php; accessed April 2006. 

University of Southern Mississippi. 2005. Tides Along the Mississippi Coast and Mississippi Sound. 

Available online at http://www.usm.edu/gcrl/MStide/tidedis.htm; accessed January 2006. 

URS. 2005. Pascagoula LNG Environmental Site Assessment, Final Report. Casotte Landing. April 

2005. 

Whale and Dolphin Conservation Society. 2004. Oceans of Noise 2004 – A WDCS Science Report. 

Editors M. Simmonds, S. Dolman, and L. Weilgart. Wiltshire, England. 

Word J., W. W. Gardiner, and D. W. Moore. 2005. Influence of Confounding Factors on SQGs and 

Their Application to Estuarine and Marine Sediment Evaluations. In Use of Sediment Quality 

Guidelines and Related Tools for the Assessment of Contaminated Sediments. Edited by R. J. 

Wenning, G. E. Batley, C. G. Ingersill, and D. W. Moore. Society of Toxicology and Chemistry. 

Pensacola, Florida. 

Yang, C.C. and Z. Huang. 2004. Lower Emission LNG Vaporization. LNG Journal, 

November/December: 24-26. 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX J 

LIST OF PREPARERS 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX J 

List of Preparers 

J-1

Federal Energy Regulatory Commission (FERC)

Button, Van T. – Cultural Resources, Socioeconomics 

 M.A., Anthropology, 1976, University of Arizona 

 B.A., Anthropology, 1973, Reed College 

Manco, Magdalene - Air and Noise Analysis 

B.S., Environmental Systems Engineering, 2004, Pennsylvania State University 

Nguyen, Thach – Reliability and Safety 

B.S., Mechanical Engineering, 2004, University of Texas at Austin 

Peconom, John - Water Resources, Vegetation and Wildlife, Threatened and Endangered Species

B.S., Environmental Biology & Management, 2000, University of California at Davis 

Thomas, Hugh V. – Reliability and Safety 

M.E., Mechanical/Environmental Engineering, 1999, University of Maryland 

B.S., Mechanical Engineering, 1991, University of Maryland 

B.S., Physical Science, 1990, Salisbury State University 

ENTRIX, Inc.

Loveday, H. Trevor – Project Manager, Project Scope, Cumulative Impacts 

M.S., Aquatic Biology, 1995, Stephen F. Austin State University 

B.B.A., Finance, 1990, Baylor University 

Dilts, Erik – Deputy Project Manager, Alternatives 

M.S., Forest Resources (Fisheries), 1999, University of Georgia 

B.S., Biology, 1995, Oglethorpe University 

Allen, Anne – Reliability and Safety, Project Coordinator 

B.S., Business Administration, 2001, Minor, Philosophy, University of Florida 

Craig, Donald – Cultural Resources 

M.A., Anthropology, Anticipated 2006, University of Southern Mississippi 

 B.A., English, 1990, Minor, History Oregon State University 

Kacher, Michael – Geology, Soils 

B.S., Geology, 2004, Baylor University 

Lifton, Zach – Threatened and Endangered Species 

M.S., Geology, 2005, Idaho State University

B.A., Geology, 2003, Oberlin College

Mooneyhan, Doug – Biological Resources Lead, Fish and Wildlife, Water Resources 

M.S., Biology, 1989, Tennessee Technological University 

B.S., Wildlife & Fisheries Science, 1987, Minor, Zoology, University of Tennessee 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX J 

List of Preparers 

J-2

Murray, Mary Kay – Vegetation and Wetlands 

M.S., Environmental Sciences, 1996, Johns Hopkins University 

B.S., Biology, 1990, Minor, Chemistry Old Dominion University 

Wakefield, Jeffery – Social Sciences Lead 

Ph.D., Economics, 2001, University of Delaware 

M.A., Environmental Economics, 1998, University of Delaware 

M.S., Marine Biology and Biochemistry, 1996, University of Delaware 

B.S., Biology, 1994, Rochester Institute of Technology

Ward, Jennifer – Socioeconomics, Land Use 

M.S., Resource Economics and Policy, Anticipated 2006, University of Maine 

B.A., Mathematics, 2001, University of North Carolina 

Willoughby, Craig – Air Quality, Noise 

 B.S., Mining Engineering, University of Missouri-Rolla 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

SUBJECT INDEX 

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

Subject Index

aboveground facility ................................................................................. ES-4, ES-5, 1-8, 2-15, 2-30, 2-36, 

2-40, 2-41, 3-30, 3-31, 4-6, 4-10, 4-30, 4-158, 4-170, 4-181, 5-5 

ABSG .......................................................................................................................................4-152, 4-153 

access road ............................................................................................................................ 2-19, 4-77, 5-13 

Advisory Council on Historic Preservation (ACHP)................................................................ 1-6, 1-7, 4-89 

air quality ........................................................................ ES-6, ES-7, 1-4, 3-5, 3-27, 4-91, 4-92, 4-93, 4-97, 

4-100, 4-101, 4-103, 4-145, 4-178, 4-179, 4-180, 5-7, 5-8 

Air quality control regions (AQCRs).......................................................................................................4-92 

allision ..................................................................................................................................................4-151 

alternatives ........................................................................... ES-1, ES-2, ES-3, ES-9, ES-10, 1-3, 1-4, 1-11, 

1-12, 2-8, 2-26, 3-1, 3-2, 3-3, 3-4, 3-5, 3-6, 3-7, 3-10, 3-11, 3-12, 3-14, 3-16, 3-17, 3-18, 3-19, 

3-21, 3-23, 3-24, 3-26, 3-27, 3-28, 3-30, 3-31, 3-33, 3-34, 3-35, 4-36, 4-47, 4-91, 4-144, 4-155, 

5-1, 5-10, 5-11, 5-12 

American Petroleum Institute (API) ....................................................... 2-20, 2-29, 2-30, 2-33, 2-39, 4-121 

American Society of Mechanical Engineers (ASME) .......................................................... 2-20, 2-30, 2-33 

Area Maritime Security Committee (AMSC).........................................................2-1, 3-1, 4-87, 4-141, 5-9 

bald eagle ..................................................................................................ES-5, 4-58, 4-66, 4-72, 4-171, 5-4 

ballast .......................................................................................................................................4-131, 4-149 

ballast water ..............................................................................2-12, 2-13, 4-26, 4-27, 4-49, 4-50, 4-64, 5-3 

Bayou Casotte ............................................................................ ES-1, ES-2, ES-3, ES-4, ES-5, ES-6, ES-7, 

ES-8, ES-9, ES-10, ES-11, ES-12, ES-13, 1-1, 1-2, 1-4, 1-6, 1-11, 1-14, 2-1, 2-2, 2-8, 2-10, 2-13, 

2-14, 2-15, 2-18, 2-19, 2-20, 2-25, 2-26, 2-28, 2-29, 2-30, 2-32, 2-33, 2-34, 2-35, 2-36, 2-37, 

2-40, 2-41, 3-1, 3-2, 3-3, 3-6, 3-9, 3-10, 3-18, 3-19, 3-21, 3-23, 3-24, 3-25, 3-26, 3-27, 3-28, 3-30, 

3-31, 3-33, 3-34, 3-35, 4-1, 4-2, 4-3, 4-5, 4-6, 4-7, 4-8, 4-10, 4-11, 4-12, 4-13, 4-16, 4-17, 4-18, 

4-19, 4-20, 4-21, 4-22, 4-23, 4-24, 4-25, 4-26, 4-27, 4-28, 4-30, 4-31, 4-33, 4-34, 4-35, 4-36, 

4-37, 4-38, 4-39, 4-40, 4-41, 4-42, 4-43, 4-44, 4-45, 4-46, 4-47, 4-48, 4-49, 4-50, 4-51, 4-52, 

4-53, 4-54, 4-58, 4-61, 4-62, 4-63, 4-64, 4-65, 4-66, 4-67, 4-72, 4-73, 4-76, 4-77, 4-78, 4-79, 

4-80, 4-82, 4-84, 4-85, 4-86, 4-87, 4-88, 4-89, 4-90, 4-93, 4-94, 4-96, 4-97, 4-100, 4-101, 4-103, 

4-104, 4-105, 4-111, 4-112, 4-114, 4-115, 4-119, 4-120, 4-121, 4-125, 4-126, 4-127, 4-128, 

4-129, 4-131, 4-132, 4-133, 4-134, 4-135, 4-136, 4-137, 4-139, 4-140, 4-141, 4-142, 4-143, 

4-144, 4-147, 4-153, 4-154, 4-155, 4-159, 4-160, 4-165, 4-166, 4-167, 4-168, 4-169, 4-171, 

4-172, 4-173, 4-174, 4-175, 4-176, 4-177, 4-181, 4-182, 5-1, 5-2, 5-3, 5-4, 5-5, 5-6, 5-7, 5-8, 5-9, 

5-10, 5-11, 5-12, 5-13, 5-14, 5-15, 5-16, 5-17, 5-18, 5-20, 5-21 

Bayou Casotte Dredged Material Management Site (BCDMMS)..................3-19, 3-21, 3-33, 4-168, 4-169 

Bayou Casotte Energy, LLC (Bayou Casotte Energy)....................................................... ES-1, ES-2, ES-3, 

ES-4, ES-5, ES-6, ES-7, ES-8, ES-9, ES-10, ES-11, ES-12, ES-13, 1-1, 1-2, 1-4, 1-6, 1-11, 1-14, 

2-1, 2-2, 2-8, 2-10, 2-15, 2-18, 2-20, 2-25, 2-26, 2-28, 2-30, 2-32, 2-33, 2-34, 2-35, 2-36, 2-37, 

2-40, 2-41, 3-1, 3-2, 3-3, 3-6, 3-9, 3-18, 3-19, 3-21, 3-23, 3-24, 3-25, 3-26, 3-27, 3-28, 3-30, 3-31, 

3-33, 3-34, 3-35, 4-1, 4-2, 4-3, 4-5, 4-6, 4-7, 4-8, 4-10, 4-11, 4-12, 4-13, 4-16, 4-17, 4-18, 4-20, 

4-21, 4-22, 4-23, 4-24, 4-25, 4-26, 4-28, 4-30, 4-31, 4-33, 4-34, 4-35, 4-36, 4-37, 4-38, 4-39, 

4-40, 4-42, 4-44, 4-45, 4-46, 4-47, 4-48, 4-49, 4-50, 4-51, 4-52, 4-53, 4-54, 4-58, 4-62, 4-63, 

K-1

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

Subject Index

4-64, 4-65, 4-66, 4-67, 4-72, 4-73, 4-76, 4-77, 4-78, 4-80, 4-82, 4-84, 4-85, 4-87, 4-88, 4-89, 

4-90, 4-93, 4-94, 4-96, 4-97, 4-100, 4-101, 4-103, 4-104, 4-105, 4-111, 4-112, 4-114, 4-115, 

4-119, 4-120, 4-121, 4-125, 4-126, 4-127, 4-128, 4-129, 4-131, 4-132, 4-133, 4-134, 4-135, 

4-136, 4-137, 4-139, 4-140, 4-141, 4-142, 4-143, 4-144, 4-147, 4-153, 4-154, 4-155, 4-159, 

4-160, 4-168, 4-171, 4-172, 4-173, 4-175, 4-177, 4-182, 5-1, 5-2, 5-3, 5-4, 5-5, 5-6, 5-7, 5-8, 5-9, 

5-10, 5-11, 5-12, 5-13, 5-14, 5-15, 5-16, 5-17, 5-18, 5-20, 5-21 

berth ........................................................................................................................... 4-149, 4-150, 4-152 

best management practices (BMPs)........................................................ ES-3, ES-7, 4-13, 4-21, 4-22, 4-26, 

4-28, 4-45, 4-48, 4-51, 4-64, 4-101, 4-168, 4-178 

billion cubic feet per day.................................................................. ES-1, ES-2, 1-1, 3-2, 3-3, 3-7, 3-8, 3-9, 

3-10, 3-12, 3-13, 3-14, 3-15, 3-16, 3-18, 3-27 

bore method .............................................................................................................................................2-35 

Breton National Wildlife Refuge ..................................................................................ES-6, ES-7, 4-94, 5-7 

British thermal units (Btu) ...................................................................ES-8, 2-8, 4-94, 4-128, 4-129, 4-134, 

4-147, 4-152, 4-153, 4-154, 4-155, 5-8 

British thermal units per square foot per hour ............................................................... 4-128, 4-129, 4-134, 

4-147, 4-152, 4-153, 4-154, 4-155 

brown pelican.......................................................................................................................ES-5, 4-38, 4-40, 

4-58, 4-66, 4-67, 4-72, 4-171, 5-4 

Captain of the Port (COTP) .................................................................... ES-9, 1-5, 1-8, 2-1, 3-1, 3-4, 4-73, 

4-87, 4-133, 4-134, 4-139, 4-140, 4-141, 4-142, 4-143, 4-144, 4-156, 5-10, 5-11, 5-17 

carbon dioxide (CO2) ........................................................................................2-14, 3-5, 3-24, 4-131, 4-150 

carbon monoxide (CO) .................................................................... ES-6, 3-5, 3-24, 4-91, 4-92, 4-96, 4-99, 

4-100, 4-102, 4-103, 4-104, 4-178, 4-179, 4-180 

cathodic protection............................................................................................................ 2-41, 4-162, 4-163 

Certificate...............................................................................................................................................4-131 

Certificate of Inspection (COI) .......................................................................................................2-15, 2-40 

Certificate of Public Convenience and Necessity (Certificate).........................2-15, 2-40, 3-2, 4-131, 4-148 

Chevron U.S.A., Inc. (Chevron) ......................................................... ES-2, ES-3, ES-5, ES-10, ES-13, 1-1, 

1-2, 2-2, 2-9, 2-17, 3-2, 3-11, 3-18, 3-23, 3-25, 3-26, 3-28, 3-30, 3-33, 4-5, 4-16, 4-22, 4-26, 4-29, 

4-34, 4-51, 4-73, 4-78, 4-80, 4-81, 4-86, 4-94, 4-137, 4-155, 4-166, 4-169, 4-171, 4-172, 4-173, 

5-5, 5-10 

City of Pascagoula .............................................................................. ES-1, ES-2, ES-3, ES-5, ES-6, ES-7, 

ES-8, ES-9, ES-10, ES-11, ES-12, ES-13, 1-1, 1-4, 1-11, 1-14, 2-1, 2-2, 2-10, 2-25, 2-26, 3-1, 

3-4, 3-9, 3-10, 3-11, 3-12, 3-18, 3-21, 3-23, 3-25, 3-28, 3-30, 3-33, 3-34, 4-5, 4-16, 4-19, 4-21, 

4-22, 4-26, 4-28, 4-29, 4-34, 4-40, 4-42, 4-50, 4-51, 4-53, 4-63, 4-73, 4-77, 4-78, 4-79, 4-80, 

4-81, 4-82, 4-83, 4-84, 4-85, 4-86, 4-87, 4-91, 4-92, 4-132, 4-133, 4-135, 4-136, 4-137, 4-138, 

4-139, 4-141, 4-142, 4-143, 4-147, 4-154, 4-155, 4-159, 4-165, 4-166, 4-167, 4-168, 4-169, 

4-172, 4-173, 4-174, 4-175, 4-176, 4-177, 4-178, 4-179, 4-180, 4-181, 5-1, 5-2, 5-5, 5-6, 5-8, 5-9, 

5-10, 5-11 

Clean Air Act (CAA) ..................................................................1-7, 1-8, 1-10, 4-92, 4-93, 4-95, 4-96, 4-98 

K-2

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

Subject Index

Clean Air Act Amendments (CAAA).............................................................................................4-95, 4-96 

Clean Water Act (CWA)..................................................................... ES-4, 1-7, 1-8, 1-10, 4-30, 4-170, 5-1 

Coastal Management Program (CMP)........................................................ES-6, 1-6, 4-80, 4-144, 5-5, 5-17 

Coastal Zone Management Act of 1972 (CZMA) ...........................................................1-5, 1-6, 1-7, 4-144 

Code of Federal Regulations (CFR).........................................................ES-1, ES-9, 1-3, 1-5, 1-6, 1-7, 1-8, 

2-1, 2-15, 2-20, 2-36, 2-37, 2-38, 2-39, 2-40, 3-1, 3-27, 4-24, 4-25, 4-87, 4-89, 4-93, 4-94, 4-95, 

4-96, 4-97, 4-98, 4-111, 4-114, 4-121, 4-125, 4-128, 4-130, 4-131, 4-133, 4-135, 4-139, 4-140, 

4-143, 4-150, 4-155, 4-156, 4-158, 4-161, 4-181, 5-9, 5-10, 5-18 

COE ..................................................................................................................................................4-138 

collision................................................................................................................4-130, 4-150, 4-151, 4-152 

compensatory mitigation...................................................................................................ES-4, 4-170, 4-182 

containment........................................................................ 4-113, 4-120, 4-121, 4-126, 4-150, 4-151, 4-154 

contamination....................................................................ES-3, 4-9, 4-11, 4-12, 4-17, 4-26, 4-44, 4-48, 5-2 

Council on Environmental Quality (CEQ).................................................................. ES-12, 1-3, 1-14, 4-85 

Cove Point LNG, L.P. (Cove Point) ..................................................................................... 3-7, 3-25, 4-112 

critical energy infrastructure information (CEII)...................................................4-114, 4-152, 4-156, 5-18 

Critical Habitat....................................................................................................4-47, 4-62, 4-63, 4-65, 4-72 

cryogenic............................................................................ 4-111, 4-112, 4-113, 4-114, 4-120, 4-150, 4-153 

cumulative impact.................................................................... ES-7, 1-14, 3-27, 4-53, 4-103, 4-165, 4-166, 

4-167, 4-168, 4-169, 4-170, 4-171, 4-172, 4-173, 4-174, 4-176, 4-177, 4-178, 4-180, 4-181, 4-182 

decibels on the A-weighted scale (dBA)........................ ES-7, 4-106, 4-108, 4-109, 4-110, 4-111, 5-8, 5-17 

deepwater port..........................................................................................................................................3-12 

Destin Pipeline Company, LLC (Destin).................... 2-15, 2-17, 2-19, 3-10, 3-11, 3-28, 4-77, 4-90, 4-166 

Distrigas of Massachusetts (Distrigas).......................................................................3-7, 3-25, 4-148, 4-152 

DOE ..................................................................................................................................................4-152 

DOT .......................................................................................................3-12, 4-111, 4-125, 4-126, 4-156 

dredge ....................................................................................... ES-2, ES-3, ES-4, ES-7, ES-9, ES-10, 1-7, 

1-8, 1-11, 1-12, 2-2, 2-25, 2-26, 2-28, 2-37, 3-1, 3-15, 3-16, 3-17, 3-19, 3-21, 3-23, 3-31, 3-33, 

3-34, 3-35, 4-2, 4-8, 4-12, 4-13, 4-14, 4-15, 4-17, 4-18, 4-19, 4-21, 4-22, 4-25, 4-26, 4-27, 4-28, 

4-36, 4-41, 4-42, 4-44, 4-45, 4-47, 4-49, 4-50, 4-51, 4-54, 4-62, 4-63, 4-64, 4-65, 4-66, 4-67, 

4-70, 4-72, 4-77, 4-80, 4-87, 4-89, 4-99, 4-100, 4-109, 4-133, 4-166, 4-167, 4-168, 4-169, 4-172, 

4-173, 4-174, 4-176, 5-1, 5-2, 5-8, 5-10, 5-11, 5-16 

easement................................................................................................................4-7, 4-11, 4-24, 4-73, 4-83 

Emergency Group Sites (EGS) ................................................................................................................4-83 

emergency response..................................................................... ES-9, 1-14, 2-41, 3-1, 4-85, 4-114, 4-135, 

4-136, 4-155, 4-157, 4-160, 4-165, 4-176, 4-182, 5-10, 5-18, 5-20 

Emergency Response Plan.........................ES-9, 1-10, 4-85, 4-135, 4-136, 4-147, 4-176, 4-182, 5-20, 5-21 

eminent domain........................................................................................................................................4-83 

K-3

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

Subject Index

emissions......................................................................... ES-6, ES-7, 1-8, 1-13, 2-13, 2-17, 3-5, 3-24, 3-25, 

3-26, 3-27, 4-92, 4-93, 4-94, 4-95, 4-96, 4-97, 4-98, 4-99, 4-100, 4-101, 4-102, 4-103, 4-104, 

4-105, 4-144, 4-178, 4-179, 4-180, 4-181, 4-182, 5-7, 5-8, 5-17 

Endangered Species Act of 1973 (ESA) ................................................................................... 1-5, 1-6, 4-54 

Energy Information Administration (EIA) ....................................................... 1-2, 1-3, 3-3, 3-5, 3-6, 4-176 

Energy Policy Act of 2005 (EPAct).................................................................ES-9, 1-8, 1-14, 4-135, 4-147

Environmental Impact Statement (EIS) ................................................................... ES-1, ES-2, ES-4, ES-5, 

ES-9, ES-11, ES-12, ES-13, 1-3, 1-4, 1-6, 1-7, 1-11, 1-12, 1-13, 1-14, 2-20, 2-30, 2-34, 2-36, 3-1, 

3-3, 3-4, 3-9, 3-13, 3-34, 4-1, 4-5, 4-7, 4-8, 4-10, 4-11, 4-17, 4-18, 4-21, 4-22, 4-23, 4-24, 4-26, 

4-30, 4-34, 4-35, 4-36, 4-39, 4-40, 4-42, 4-44, 4-47, 4-51, 4-52, 4-53, 4-54, 4-76, 4-78, 4-81, 

4-86, 4-87, 4-141, 4-148, 4-151, 4-152, 4-154, 4-165, 4-166, 5-2, 5-3, 5-4, 5-10, 5-11, 5-12, 5-13, 

5-16, 5-17, 5-18, 5-19, 5-20, 5-21, 5-22 

Environmental Inspector (EI)................................................................................2-36, 4-7, 4-10, 5-14, 5-15 

erosion ....................................................................................................ES-2, 2-25, 2-30, 2-32, 2-34, 2-35, 

4-2, 4-5, 4-6, 4-7, 4-8, 4-10, 4-11, 4-17, 4-18, 4-19, 4-21, 4-23, 4-24, 4-26, 4-27, 4-30, 4-34, 4-35, 

4-40, 4-44, 4-47, 4-48, 4-64, 4-67, 4-78, 4-167, 4-169, 5-2 

Essential Fish Habitat (EFH) ................................ ES-5, 1-6, 3-19, 4-42, 4-43, 4-52, 4-53, 4-173, 5-4, 5-16 

Excelerate Energy, LLC (Excelerate) .............................................................................................3-12, 3-13 

Facility Security Officer (FSO)....................................................................................... 4-132, 4-134, 4-156 

Federal Emergency Management Agency (FEMA) .........................................................................4-5, 4-83 

Federal Energy Regulatory Commission (FERC or Commission) .............................................. ES-1, ES-2, 

ES-3, ES-5, ES-6, ES-7, ES-9, ES-10, ES-11, ES-12, ES-13, 1-1, 1-3, 1-4, 1-5, 1-6, 1-7, 1-10, 

1-11, 1-14, 1-15, 2-1, 2-17, 2-18, 2-34, 2-36, 3-1, 3-2, 3-3, 3-6, 3-7, 3-8, 3-9, 3-11, 3-12, 3-14, 

3-17, 3-27, 3-28, 3-34, 4-1, 4-7, 4-8, 4-22, 4-23, 4-24, 4-25, 4-35, 4-48, 4-50, 4-51, 4-52, 4-53, 

4-54, 4-64, 4-66, 4-67, 4-73, 4-78, 4-79, 4-81, 4-82, 4-83, 4-86, 4-87, 4-88, 4-89, 4-94, 4-103, 

4-106, 4-108, 4-109, 4-111, 4-112, 4-114, 4-117, 4-118, 4-119, 4-120, 4-121, 4-126, 4-128, 

4-130, 4-134, 4-135, 4-136, 4-141, 4-142, 4-143, 4-144, 4-147, 4-150, 4-152, 4-154, 4-155, 

4-156, 4-157, 4-158, 4-167, 4-179, 5-1, 5-4, 5-5, 5-7, 5-8, 5-9, 5-10, 5-12, 5-14, 5-15, 5-16, 5-17, 

5-20, 5-21, 5-22 

Federal Maritime Security Coordinators (FMSC) .............................................................. 1-5, 4-140, 4-142 

Federal Power Commission (FPC) ........................................................................................................4-150 

Federal Register (FR)........................................................ES-1, ES-11, ES-12, 1-1, 1-3, 1-11, 4-140, 4-159 

firewater ......................................................................................................................................4-131, 4-150 

fish ....................................................................................................................................................4-61 

Fisheries ................................................................................................................................ 4-52, 4-54, 4-59 

flammable vapor cloud .............................................................................4-112, 4-129, 4-151, 4-152, 4-154 

floating storage and regasification units ..................................................................................................3-12 

floating, storage, and regasification unit (FSRU) ....................................................................................3-16 

flood .................................... 2-12, 2-32, 4-5, 4-6, 4-10, 4-48, 4-62, 4-67, 4-118, 4-138, 4-164, 5-2, 5-22 

GBS ....................................................................................................................................................3-12 

K-4

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

Subject Index

geologic hazards............................................................................................................ ES-2, 4-3, 4-162, 5-2 

Grand Bay National Estuarine Research Reserve....................................................................................4-67 

Grand Bay Preserve ....................................................................................................................4-166, 4-171 

gravity-based structure (GBS) .............................................................................................. 3-12, 3-15, 3-17 

gravity-based structures ...........................................................................................................................3-12 

Guidance on Risk Analysis and Safety Implications of a Large Liquefied 

Natural Gas (LNG) Spill Over Water (Sandia Report)...........................4-134, 4-147, 4-151, 4-153 

Gulf Intracoastal Waterway (GIWW)........................................................ ES-6, ES-9, 2-1, 3-4, 4-176, 5-11 

Gulf Islands National Seashore.......................................................................................................1-13, 4-78 

Gulf LNG Energy, LLC (Gulf LNG)....................................................................................... 1-4, 3-9, 3-10 

Gulf LNG Energy, LLC or Gulf LNG Pipeline, LLC (Gulf LNG) ......................................... 1-4, 3-9, 3-10, 

3-11, 4-65, 4-78, 4-135, 4-138, 4-155, 4-166, 4-169, 4-171, 4-172, 4-173, 4-174, 4-175, 4-177, 

4-180, 5-7, 5-12 

Gulf LNG Pipeline, LLC (Gulf LNG) ......................................................................................................1-4 

Gulf of Mexico Fishery Management Council (GMFMC)......................................................................4-52 

Gulf sturgeon ............................................................................................................. ES-5, 1-11, 1-13, 3-17, 

3-34, 4-19, 4-58, 4-60, 4-62, 4-63, 4-64, 4-171, 4-172, 5-4 

Gulfstream Natural Gas System, LLC (Gulfstream)...................................................2-15, 2-17, 2-18, 2-20, 

3-10, 3-11, 3-27, 3-28, 3-30, 4-23, 4-39, 4-73, 4-76, 4-77, 4-166 

Hazardous Air Pollutants (HAPs)............................................................................4-95, 4-96, 4-100, 4-178 

HDD ................................................................................................................................. 4-33, 4-55, 4-56 

high consequence areas (HCAs) .................................................................................................4-159, 4-160 

horizontal directional drill (HDD) .........................................................................................................4-169 

Horn Island .................................................................................. ES-3, ES-8, ES-9, ES-11, 1-11, 2-1, 2-10, 

2-25, 2-37, 3-1, 3-34, 4-6, 4-22, 4-27, 4-29, 4-38, 4-42, 4-48, 4-78, 4-86, 4-87, 4-90, 4-132, 

4-133, 4-135, 4-136, 4-137, 4-138, 4-141, 4-142, 4-143, 4-147, 4-154, 4-170, 4-181, 5-1, 5-2, 5-6, 

5-7, 5-8, 5-9, 5-10 

Horn Island Pass ............................................................................. ES-8, ES-9, ES-11, 1-11, 2-1, 2-10, 3-1, 

4-78, 4-86, 4-87, 4-90, 4-132, 4-133, 4-135, 4-136, 4-137, 4-138, 4-141, 4-142, 4-143, 4-147, 

4-154, 5-1, 5-6, 5-7, 5-8, 5-9, 5-10 

Human Machine Interface........................................................................................................................2-39 

hurricane ....................................................................... ES-2, ES-3, 1-13, 2-10, 2-18, 2-25, 2-26, 3-31, 4-2, 

4-5, 4-6, 4-19, 4-26, 4-28, 4-33, 4-48, 4-77, 4-91, 4-99, 4-116, 4-119, 4-125, 4-127, 4-165, 4-167, 

4-175, 5-2, 5-6, 5-19 

Hurricane Katrina....................................................................................... 4-6, 4-19, 4-28, 4-31, 4-81, 4-82, 

4-83, 4-84, 4-85, 4-88, 4-165, 4-166, 4-167, 4-174, 4-175, 4-177, 5-5, 5-6 

impoundment system .............................................................................................................................4-126 

International Convention for the Safety of Life at Sea (SOLAS)....................................... 2-14, 2-40, 4-131 

International Maritime Organization (IMO) ..................................................................... 2-40, 4-131, 4-150 

K-5

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

Subject Index

Invasive....................................................................................................................................................4-30 

Jackson County Port Authority (JCPA)...........................................................ES-1, 1-3, 1-10, 4-168, 4-174 

least tern...................................................................................................................................................4-67 

letter of intent (LOI).....................................................................................................1-5, 4-140, 4-154, 5-9 

Letter of Recommendation (LOR)..................................................................ES-1, ES-8, ES-9, ES-10, 1-2, 

1-4, 1-5, 1-8, 1-11, 2-1, 3-1, 3-2, 3-3, 3-4, 4-73, 4-79, 4-87, 4-111, 4-132, 4-133, 4-135, 4-137, 

4-139, 4-140, 4-141, 4-142, 4-143, 4-144, 4-148, 4-154, 4-155, 4-181, 5-1, 5-9, 5-10, 5-11 

liquefied natural gas (LNG) ..................................................................................... ES-1, ES-2, ES-3, ES-4, 

ES-5, ES-6, ES-7, ES-8, ES-9, ES-10, ES-11, ES-12, ES-13, 1-1, 1-2, 1-3, 1-4, 1-5, 1-6, 1-7, 1-8, 

1-11, 1-12, 1-13, 1-14, 1-15, 2-1, 2-2, 2-4, 2-5, 2-6, 2-7, 2-8, 2-9, 2-10, 2-12, 2-13, 2-14, 2-15, 

2-18, 2-19, 2-20, 2-25, 2-26, 2-28, 2-29, 2-30, 2-36, 2-37, 2-38, 2-39, 2-40, 3-1, 3-2, 3-3, 3-4, 3-5, 

3-6, 3-7, 3-8, 3-9, 3-10, 3-11, 3-12, 3-13, 3-14, 3-15, 3-16, 3-17, 3-18, 3-19, 3-21, 3-23, 3-24, 

3-25, 3-26, 3-27, 3-28, 3-31, 4-1, 4-2, 4-3, 4-4, 4-5, 4-6, 4-7, 4-8, 4-9, 4-10, 4-11, 4-12, 4-13, 

4-16, 4-17, 4-18, 4-19, 4-21, 4-22, 4-23, 4-24, 4-25, 4-26, 4-27, 4-28, 4-29, 4-31, 4-33, 4-34, 

4-36, 4-38, 4-39, 4-40, 4-42, 4-44, 4-47, 4-48, 4-49, 4-50, 4-51, 4-53, 4-54, 4-55, 4-56, 4-57, 

4-58, 4-59, 4-60, 4-61, 4-62, 4-64, 4-65, 4-66, 4-68, 4-69, 4-70, 4-71, 4-72, 4-73, 4-76, 4-77, 

4-78, 4-79, 4-80, 4-81, 4-83, 4-85, 4-86, 4-87, 4-88, 4-89, 4-90, 4-93, 4-94, 4-95, 4-96, 4-97, 

4-99, 4-100, 4-101, 4-102, 4-103, 4-106, 4-109, 4-110, 4-111, 4-112, 4-113, 4-114, 4-115, 4-116, 

4-117, 4-118, 4-119, 4-120, 4-121, 4-125, 4-126, 4-127, 4-128, 4-129, 4-130, 4-131, 4-132, 

4-133, 4-134, 4-135, 4-136, 4-137, 4-138, 4-139, 4-140, 4-141, 4-142, 4-143, 4-144, 4-145, 

4-147, 4-148, 4-149, 4-150, 4-151, 4-152, 4-153, 4-154, 4-155, 4-156, 4-157, 4-164, 4-165, 

4-166, 4-167, 4-168, 4-169, 4-170, 4-171, 4-172, 4-173, 4-174, 4-175, 4-176, 4-177, 4-178, 

4-179, 4-180, 4-181, 4-182, 5-1, 5-2, 5-3, 5-4, 5-5, 5-6, 5-7, 5-8, 5-9, 5-10, 5-11, 5-12, 5-15, 5-17, 

5-18, 5-19, 5-20, 5-21, 5-22 

LNG storage tank.................................................................................ES-1, ES-5, 1-1, 2-2, 2-5, 2-19, 2-20, 

2-25, 2-26, 2-29, 2-38, 3-15, 3-21, 4-2, 4-4, 4-6, 4-8, 4-17, 4-21, 4-24, 4-76, 4-95, 4-99, 4-101, 

4-111, 4-113, 4-119, 4-120, 4-121, 4-125, 4-126, 4-127, 4-128, 4-135, 4-155, 4-174, 5-5, 5-22 

LNG storage tanks .......................................................................... 3-15, 4-119, 4-120, 4-125, 4-126, 4-127 

LNGFIRE III..........................................................................................................................................4-128 

lower flammability limit (LFL)......................................................................ES-8, 4-129, 4-130, 4-154, 5-8 

Magnuson-Stevens Fishery Conservation and Management Act (MSA) ..........................1-5, 1-6, 1-7, 4-52 

Marine Construction Monitoring ............................................................................................................ ES-5 

marine mammals....................................................................................... 1-7, 1-12, 4-58, 4-62, 4-72, 4-145 

Marine Protection, Research and Sanctuaries Act of 1972, as amended (MPRSA).................. ES-3, ES-10, 

1-7, 3-34, 3-35, 4-12, 4-22, 4-28, 4-51, 5-1, 5-2, 5-11 

marine transportation .............................................................................................................................4-130 

Maritime Security (MARSEC) ....................................................... 4-134, 4-141, 4-142, 4-156, 4-157, 5-17 

membrane tank............................................................................................................................4-120, 4-151 

Memorandum of Understanding on Natural Gas Transportation Facilities (Memorandum).................4-158 

methane........................................................................................................................... 4-113, 4-129, 4-151 

migratory birds...............................................................................................................1-7, 4-37, 4-39, 4-72 

K-6

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

Subject Index

milepost (MP) ............................................................................................. 1-6, 2-15, 2-17, 2-18, 4-76, 4-96 

Minerals Management Service (MMS)....................................................................................................4-72 

minimum striking speed.........................................................................................................................4-151 

Mississippi Department of Environmental Quality (MDEQ) ...................................ES-1, ES-3, ES-12, 1-3, 

1-8, 1-9, 1-10, 1-14, 2-9, 2-29, 2-33, 4-11, 4-13, 4-16, 4-17, 4-18, 4-19, 4-21, 4-23, 4-25, 4-26, 

4-28, 4-39, 4-41, 4-45, 4-48, 4-50, 4-51, 4-64, 4-93, 4-97, 4-101, 4-166, 4-178, 5-8, 5-16 

Mississippi Department of Marine Resources (MDMR)..........................................ES-1, ES-6, ES-12, 1-3, 

1-9, 1-14, 3-33, 3-34, 4-12, 4-13, 4-21, 4-22, 4-23, 4-28, 4-29, 4-35, 4-36, 4-38, 4-39, 4-44, 4-45, 

4-49, 4-50, 4-51, 4-53, 4-54, 4-64, 4-80, 4-144, 5-5, 5-16, 5-17 

Mississippi Department of Transportation (MDOT) ..........................................................................1-9, 5-6 

Mississippi Natural Heritage Program (MNHP)......................................................................................4-65 

Mississippi Power Company (MPC).............2-8, 2-17, 2-18, 3-27, 3-30, 4-23, 4-39, 4-74, 4-75, 4-76, 5-15 

Mississippi Sound ................................................................... ES-7, 3-34, 4-6, 4-19, 4-22, 4-27, 4-29, 4-40, 

4-41, 4-42, 4-43, 4-49, 4-63, 4-64, 4-66, 4-133, 4-136, 4-137, 4-138, 4-169, 4-172, 4-173, 4-174, 

5-3 

Mississippi State Historic Preservation Office (SHPO).......................................ES-6, 4-89, 4-90, 4-91, 5-7 

monitoring....................................................................................................................... 4-131, 4-155, 4-157 

National Ambient Air Quality Standards (NAAQS) .................................................ES-6, ES-7, 4-91, 4-92, 

4-93, 4-97, 4-98, 4-103, 4-104, 4-105, 4-145, 4-178, 4-179, 4-180, 4-181, 5-7 

National Emission Standards for Hazardous Air Pollutants (NESHAPs) ...............................................4-96 

National Environmental Policy Act (NEPA) ...................................................ES-1, ES-10, ES-12, 1-3, 1-6, 

1-7, 1-10, 1-14, 3-1, 3-8, 3-9, 4-52, 4-86, 4-87, 4-111, 4-143, 4-144, 4-148 

National Fire Protection Association (NFPA) .................................................2-20, 2-36, 2-38, 2-39, 4-116, 

4-121, 4-125, 4-126, 4-127, 4-128, 4-129, 5-19 

National Historic Preservation Act (NHPA)..................................................... 1-5, 1-6, 1-7, 1-9, 4-89, 4-91 

National Pollutant Discharge Elimination System (NPDES) .......................................... ES-3, 1-8, 1-9, 2-9, 

4-11, 4-17, 4-18, 4-26, 4-48, 5-3 

National Register of Historic Places (NRHP)......................................................................... 1-6, 4-89, 4-90 

Native American ........................................................................................... ES-11, ES-12, 1-11, 4-81, 4-90 

Natural Gas Act (NGA) ......................................................................................1-1, 1-8, 1-14, 4-135, 4-147 

Natural Resources Conservation Service (NRCS)...........................................................2-34, 4-6, 4-8, 4-10 

Navigation and Vessel Inspection Circular - Guidance on Assessing the Suitability of a Waterway for 

Liquefied Natural Gas (LNG) Marine Traffic (NVIC 05-05)....................................... 1-5, 2-1, 3-1, 

4-87, 4-140, 4-141, 4-144, 5-9 

NEPA ..................................................................................................................................................4-111 

New Source Performance Standards (NSPS)........................................................................ 4-94, 4-95, 4-97

New Source Review (NSR) ..............................................................................................................1-9, 4-93 

NFPA ................................................................................................................4-125, 4-126, 4-128, 4-129 

K-7

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

Subject Index

nitrogen dioxide (NO2)........................................ES-6, 4-91, 4-92, 4-94, 4-103, 4-104, 4-105, 4-180, 4-181 

nitrogen oxides (NOx) .................................... 3-5, 3-24, 3-27, 4-94, 4-96, 4-99, 4-100, 4-102, 4-178, 4-179 

noise-sensitive area (NSA) ............................................ ES-7, 4-106, 4-108, 4-109, 4-110, 4-111, 5-8, 5-17 

Ocean Dredged Material Disposal Site (ODMDS)......................................................ES-3, ES-10, 1-7, 1-8, 

2-25, 2-26, 2-37, 3-21, 3-34, 3-35, 4-12, 4-14, 4-21, 4-22, 4-25, 4-28, 4-42, 4-50, 4-51, 4-53, 

4-63, 4-77, 4-168, 5-2, 5-11 

Office of Energy Projects (OEP) ................................................................. 1-4, 4-8, 4-24, 4-25, 4-39, 4-53, 

4-72, 4-73, 4-101, 4-114, 4-119, 4-135, 4-136, 4-154, 5-12, 5-13, 5-15, 5-16, 5-17, 5-18, 5-19, 

5-21, 5-22 

Office of Pipeline Safety........................................................................................................................4-126 

Office of Pipeline Safety (OPS)................................................................4-121, 4-126, 4-156, 4-157, 4-159 

operation and maintenance ..................................................................................... ES-7, 2-36, 4-101, 4-178 

OPS .......................................................................................................................................4-126, 4-156 

Our Procedures.........................................................................................................................................4-35 

ozone (O3) ..................................................................................................................4-91, 4-92, 4-93, 4-145 

particulate matter less than 10 microns in aerodynamic diameter (PM10) ..........................ES-6, ES-7, 4-91, 

4-92, 4-94, 4-96, 4-99, 4-100, 4-102, 4-103, 4-104, 4-105, 4-178, 4-179, 4-180, 4-181 

particulate matter less than 2.5 microns in aerodynamic diameter (PM2.5).....4-91, 4-92, 4-96, 4-100, 4-102 

Pascagoula Bar Channel ........................................................................................2-10, 4-132, 4-133, 4-137 

Pascagoula Bar Pilots Association (Pascagoula Pilots) ........................................4-87, 4-132, 4-133, 4-135, 

4-137, 4-138, 4-139, 4-155, 4-177, 4-182 

Petit Bois Island ............................................................................................ 4-6, 4-78, 4-90, 4-170, 5-4, 5-7 

Pipeline and Hazardous Materials Safety Administration (PHMSA)...............................ES-12, 1-14, 4-157 

Plan .................................................................................. 4-133, 4-134, 4-136, 4-156, 4-157, 5-20, 5-21 

polychlorinated biphenyls (PCBs) ...........................................................................................................4-13 

polycyclic aromatic hydrocarbons (PAHs) ..............................................................................................4-13 

Port of Pascagoula............................................................................ ES-8, 1-10, 2-11, 3-1, 4-78, 4-79, 4-86, 

4-132, 4-136, 4-137, 4-138, 4-139, 4-142, 4-145, 4-155, 4-166, 4-172, 4-174, 4-176, 4-182 

Pre-Filing Process ........................................................................................................................ES-11, 1-11 

Prevention of Significant Deterioration (PSD) ............................................. 1-9, 4-93, 4-94, 4-97, 4-98, 5-7 

Primary Constituent Elements (PCEs).....................................................................................................4-63 

public health...........................................................................................................................................4-153 

rapid phase transition (RPT) ..................................................................................................................4-114 

risk management plan (RMP) ..................................................................................................................4-96 

safety ..........................3-12, 3-16, 4-111, 4-112, 4-114, 4-130, 4-131, 4-138, 4-150, 4-153, 4-155, 4-156 

Safety Instrumented System (SIS) ..................................................................................................2-39, 2-40 

Sampling and Analysis Plan (SAP) .........................................................................................................3-33 

K-8

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

Subject Index

sea turtles ................... ES-5, 1-13, 4-42, 4-57, 4-58, 4-60, 4-61, 4-65, 4-69, 4-71, 4-145, 4-171, 4-172, 5-4 

Secretary of the Commission (Secretary) ............................................................1-14, 4-8, 4-17, 4-24, 4-28, 

4-39, 4-45, 4-49, 4-53, 4-72, 4-73, 4-89, 4-101, 4-111, 4-114, 4-117, 4-118, 4-135, 4-136, 4-154, 

5-8, 5-12, 5-13, 5-15, 5-16, 5-17, 5-18, 5-19, 5-21 

Section 103 evaluation............................................................................ ES-3, ES-10, 1-7, 1-10, 2-25, 3-34, 

3-35, 4-12, 4-22, 4-28, 4-51, 5-2, 5-11 

sendout pipeline ..................................................................3-10, 3-17, 3-23, 4-99, 4-101, 4-169, 4-171, 5-8 

shell and tube vaporization (STV) ........................................................................................ 3-24, 3-25, 3-26 

ship traffic ..............................................................................................................................................4-138 

Shipboard Oil Pollution Emergency Plan (SOPEP) .......................................................................4-62, 4-65

smalltooth sawfish ...................................................................................................................................4-42 

Society of International Gas Tanker and Terminal Operators (SIGTTO) .............................................4-151 

Soil Survey Geographic (SSURGO)......................................................................................... 4-6, 4-9, 4-11 

SOLAS ..................................................................................................................................................4-131 

Southern LNG, Inc. (Southern)..................................................................... 3-7, 3-10, 3-24, 4-3, 4-68, 4-92 

SPCC ....................................................................................................................................................4-26 

Special Management Area (SMA).......................................................................ES-6, 4-78, 4-79, 4-80, 5-5

Spill Prevention, Containment, and Countermeasures Plan (SPCC Plan) ............................ES-3, 2-25, 4-7, 

4-12, 4-18, 4-26, 4-46, 4-49, 4-65, 4-85, 4-172, 5-2, 5-3 

State Historic Preservation Office (SHPO)...................................................ES-6, 1-9, 4-89, 4-90, 4-91, 5-7 

Storm Water Pollution Prevention Plan (SWPPP)..............................................ES-3, 1-9, 2-25, 4-11, 4-21, 

4-26, 4-44, 4-48, 4-168, 5-3 

submerged combustion vaporizer (SCV).....................................................................3-10, 3-24, 3-25, 3-26

sulfur dioxide (SO2) ........................................................................ ES-6, 3-5, 4-91, 4-92, 4-94, 4-96, 4-97, 

4-99, 4-100, 4-102, 4-103, 4-104, 4-105, 4-178, 4-179, 4-180, 4-181 

sulfur oxides (SOx).................................................................................................................................4-100 

terrorism...............................................................................................................4-112, 4-131, 4-156, 4-157 

Thermal Exclusion Zone.............................................................................................................4-128, 4-129 

thermal radiation .......................................................................................4-112, 4-128, 4-152, 4-153, 4-154 

total suspended solids (TSS)............................................................ 4-13, 4-21, 4-41, 4-45, 4-64, 4-169, 5-2 

trinitrotoluene (TNT) ..................................................................................................................4-113, 4-114 

Trunkline LNG Company, LLC (Trunkline) .......................................................................... 3-7, 3-10, 3-24

U.S. Army Corps of Engineers (COE)....................................................... ES-1, ES-4, ES-12, 1-3, 1-7, 1-8, 

1-10, 1-14, 2-25, 2-26, 3-33, 3-34, 4-5, 4-12, 4-13, 4-14, 4-18, 4-21, 4-22, 4-23, 4-25, 4-28, 4-30, 

4-35, 4-36, 4-39, 4-41, 4-42, 4-44, 4-45, 4-47, 4-50, 4-51, 4-53, 4-54, 4-63, 4-64, 4-77, 4-86, 

4-138, 4-165, 4-166, 5-1, 5-2, 5-3, 5-16 

U.S. Coast Guard (Coast Guard)........................................................ ES-1, ES-2, ES-6, ES-8, ES-9, ES-10, 

ES-11, ES-12, ES-13, 1-2, 1-3, 1-4, 1-5, 1-7, 1-8, 1-11, 1-14, 2-1, 2-12, 2-13, 2-14, 2-15, 2-20, 

K-9

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

Subject Index

2-26, 2-37, 2-40, 3-1, 3-2, 3-3, 3-4, 3-12, 3-13, 3-14, 3-15, 3-16, 3-17, 4-50, 4-73, 4-79, 4-80, 

4-86, 4-87, 4-88, 4-103, 4-111, 4-130, 4-131, 4-132, 4-133, 4-134, 4-135, 4-136, 4-137, 4-138, 

4-139, 4-140, 4-141, 4-142, 4-143, 4-144, 4-145, 4-147, 4-148, 4-149, 4-150, 4-154, 4-155, 

4-156, 4-164, 4-174, 4-177, 4-178, 4-181, 4-182, 5-1, 5-5, 5-6, 5-9, 5-10, 5-11, 5-17, 5-20 

U.S. Department of Agriculture (USDA) ..................................................................................................4-6 

U.S. Department of Commerce, National Oceanic and Atmospheric 

Administration, National Marine Fisheries Service (NMFS) .............................................ES-1, 1-3 

U.S. Department of Defense (DOD)........................................................................................................1-14 

U.S. Department of Energy (DOE)..........................................................................1-2, 4-134, 4-151, 4-152 

U.S. Department of the Interior, Fish and Wildlife Service (FWS) ................................ ES-1, ES-5, ES-12, 

1-3, 1-6, 1-14, 4-23, 4-36, 4-39, 4-54, 4-55, 4-62, 4-63, 4-65, 4-66, 4-67, 4-72, 4-73, 5-4, 5-5, 

5-16, 5-17 

U.S. Department of Transportation (DOT)............................................... ES-1, ES-12, 1-3, 1-8, 1-13, 1-14, 

2-20, 2-33, 2-36, 2-37, 2-40, 2-41, 3-12, 4-24, 4-96, 4-111, 4-125, 4-126, 4-156, 4-157, 4-158, 

4-159, 4-160, 4-161, 4-163, 4-164, 4-181 

U.S. Environmental Protection Agency (EPA)...................................................... ES-1, ES-3, 1-3, 1-7, 1-8, 

1-10, 1-14, 2-25, 3-34, 3-35, 4-12, 4-15, 4-16, 4-17, 4-22, 4-25, 4-28, 4-42, 4-51, 4-77, 4-91, 

4-92, 4-93, 4-95, 4-100, 4-101, 4-103, 4-104, 4-106, 4-179, 5-1, 5-2, 5-8, 5-16 

U.S. Geological Survey (USGS)................................................................................................................4-3 

U.S. Maritime Administration (MARAD)......................................................................................3-12, 3-13 

United States Code (USC) ................................................................ ES-1, 1-5, 1-6, 4-52, 4-93, 4-96, 4-139

Upland Erosion Control, Revegetation and Maintenance Plan (Plan)............................... ES-3, ES-4, ES-6, 

ES-7, ES-9, ES-13, 1-8, 1-9, 2-1, 2-20, 2-25, 2-26, 2-30, 2-34, 2-36, 3-1, 3-4, 4-5, 4-7, 4-8, 4-10, 

4-11, 4-12, 4-17, 4-18, 4-21, 4-26, 4-30, 4-34, 4-40, 4-44, 4-46, 4-49, 4-62, 4-65, 4-79, 4-85, 

4-90, 4-100, 4-115, 4-117, 4-133, 4-134, 4-135, 4-136, 4-141, 4-142, 4-143, 4-147, 4-148, 4-155, 

4-156, 4-157, 4-167, 4-182, 5-1, 5-2, 5-3, 5-4, 5-7, 5-10, 5-11, 5-13, 5-16, 5-17, 5-18, 5-20, 5-21 

vapor dispersion...................................................................................................4-113, 4-152, 4-153, 4-154 

Vapor Dispersion Zone..........................................................................................................................4-129 

vessel security officer (VSO)......................................................................................................4-131, 4-132 

Vessel Strike Avoidance and Injured/Dead Protected Species Reporting 

Procedures (Strike Avoidance Procedures).............................................................. 4-65, 4-172, 5-5 

volatile organic compounds (VOCs)............................................ 4-16, 4-17, 4-95, 4-100, 4-101, 4-144, 5-8 

volatile organic liquids (VOLs) ...............................................................................................................4-95 

Waterway Suitability Assessment (WSA) .......................................................ES-9, 1-5, 2-1, 3-1, 3-4, 4-87, 

4-140, 4-141, 4-182, 5-9, 5-11 

well .............................................................................. ES-3, ES-5, ES-10, 1-2, 1-4, 1-5, 1-10, 2-1, 2-7, 

2-9, 2-18, 2-20, 2-26, 2-36, 2-37, 2-40, 3-2, 3-4, 3-5, 3-7, 3-10, 3-11, 3-16, 3-18, 3-19, 3-25, 3-26, 

3-28, 4-2, 4-3, 4-4, 4-6, 4-8, 4-11, 4-15, 4-16, 4-17, 4-22, 4-23, 4-28, 4-30, 4-31, 4-39, 4-42, 4-45, 

4-46, 4-48, 4-50, 4-51, 4-52, 4-60, 4-72, 4-79, 4-93, 4-94, 4-99, 4-101, 4-112, 4-114, 4-115, 

4-117, 4-130, 4-131, 4-133, 4-135, 4-136, 4-139, 4-141, 4-142, 4-143, 4-145, 4-150, 4-155, 

K-10

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
APPENDIX K 

Subject Index

4-157, 4-158, 4-159, 4-161, 4-162, 4-166, 4-168, 4-173, 4-177, 4-178, 4-180, 4-182, 5-1, 5-2, 5-3, 

5-10, 5-11, 5-12, 5-15, 5-18, 5-20 

wetland ................................................................................... ES-2, ES-4, ES-5, ES-13, 1-4, 1-7, 1-8, 1-11, 

1-12, 2-18, 2-19, 2-30, 2-34, 3-16, 3-19, 3-28, 3-30, 3-33, 4-10, 4-11, 4-17, 4-18, 4-23, 4-24, 

4-28, 4-30, 4-31, 4-33, 4-34, 4-35, 4-36, 4-37, 4-38, 4-39, 4-40, 4-51, 4-53, 4-54, 4-68, 4-69, 

4-73, 4-74, 4-75, 4-76, 4-77, 4-78, 4-89, 4-167, 4-170, 4-171, 4-173, 4-182, 5-1, 5-3, 5-4, 5-13, 

5-15 

Wetland...........................................................................................................................................4-32, 4-33 

Wetland and Waterbody Construction and Mitigation Procedures (Procedures) ........................ ES-3, ES-4, 

ES-13, 2-20, 2-34, 2-36, 2-41, 4-7, 4-10, 4-11, 4-17, 4-18, 4-23, 4-24, 4-26, 4-30, 4-35, 4-36, 

4-39, 4-40, 4-47, 4-52, 4-53, 4-76, 4-115, 5-2, 5-3, 5-4, 5-16, 5-18 

Wetlands ......................................................................................................................4-30, 4-32, 4-33, 4-35 

whales ................................................................................ ES-5, 4-58, 4-59, 4-62, 4-72, 4-171, 4-172, 5-4 

wildlife .....................................................................................................................................ES-4-38, 4-40 

K-11

Document Accession #: 20061222-4000 Filed Date: 12/22/2006
Document Content(s)

Report_Cover_and_Spine.PDF................................................1

Cover_Letter_Letter_to_the_Parties.PDF....................................4

Table_of_Contents.PDF.....................................................6

Executive_Summary.PDF....................................................22

Section_1_Introduction.PDF...............................................35

Section_2_Description.PDF................................................50

Section_3_Alternatives.PDF...............................................91

Section_4_Enviromental_Analysis.PDF.....................................126

Section_5_Conclusions.PDF...............................................308

Appendix_A_ FEIS-Distribution List.PDF..................................330

Appendix_B1_Plan Final.PDF..............................................341

Appendix_B2_Procedures Final.PDF........................................375

Appendix_C_Construction_SWPPP.PDF.......................................418

Appendix_D_Construction_SPCC_Plan.PDF...................................456

Appendix_E1_Section_103_Evaluation.PDF..................................485

Appendix_E2_DMMP.PDF....................................................616

Appendix_F_EFH_Evaluation.PDF...........................................642

Appendix_G_USCG_Letters_Combined.PDF ...................................748

Appendix_H_Comments_on_the_Draft_EIS_and_Responses.PDF..................753

Appendix_I_References.PDF...............................................805

Appendix_J_List_of_Preparers.PDF........................................812

Appendix_K_Subject_Index.PDF............................................815

Document Accession #: 20061222-4000 Filed Date: 12/22/2006