Federal Railroad Administration 

Appalachian NGL Hub Rail Transloading Facility 

FINDING OF NO SIGNIFICANT IMPACT 

Submitted Pursuant to 42 U.S.C. 4332 (2)(c) 

By the 

U.S. Department of Transportation 

Federal Railroad Administration 
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Finding of No Significant Impact

Appalachian NGL HUB Rail Transloading Facility

August 2020

1. INTRODUCTION 

The proposed Appalachian NGL Hub Rail Transloading Project (the Project) will be constructed 

by Ohio River Partners Shareholder LLC (doing business as Long Ridge Energy Terminal (LRET)) 

to support the continued need for transportation of Natural Gas Liquids (NGL) to end-use markets. 

The Project consists of the construction of a new transloading facility (the Transloading Facility) 

in Hannibal, Ohio, for which funds have been awarded to Monroe County by the Federal Railroad 

Administration (FRA). Additionally, the Project includes an associated, privately-funded 10-inch 

diameter pipeline (the NGL Pipeline). The NGL Pipeline will transport NGLs from the existing gas 

processing facility owned by Blue Racer Midstream (Blue Racer) in Natrium, West Virginia, 

crossing under the Ohio River into Ohio and ultimately terminating approximately 5.9 miles to the 

southeast at the new Transloading Facility (Figure 1). The Transloading Facility will facilitate 

loading NGLs from the pipeline onto railcars for shipment out of the region to extra-regional 

processing facilities and end-use markets. 

In 2018, Monroe County, Ohio was selected for a grant from the US Department of 

Transportation’s (US DOT) Better Utilizing Investments to Leverage Development (BUILD) 

program for grant funding for construction of the Project. The $20 million grant, administered 

through the FRA, offsets the total cost of approximately $40 million for the Transloading Facility. 

The construction of the NGL pipeline is also a part of the Project, but only the Transloading Facility 

is Federally-funded. 

Therefore, FRA must comply with the National Environmental Policy Act (NEPA) (42 U.S.C. § 

4321 et seq.) prior to authorizing Monroe County to use DOT funds and commence construction 

of the Project. NEPA requires federal agencies to consider the impacts of their actions on the 

natural, social, economic, and cultural environment and to disclose those considerations in a 

public document. The NEPA process helps public officials make decisions with an understanding 

of the potential environmental impacts. 

This Finding of No Significant Impact (FONSI) has been prepared to comply with the NEPA, as 

amended, 42 U.S.C. §§ 4321 et seq., its implementing regulations (40 CFR parts 1500-1508); 23 

CFR Parts 771 and 774; and related laws. FRA has made this FONSI based on information 

included in the Environmental Assessment (EA). The EA is incorporated by reference to this 

FONSI. 
PGH X:IGIS\LONG RIDGE ENERGY\212C-CF-00264 - LONG RIDGE ENERGY TERMINAL TRANSLOADING\NEW FIGS\1.2.1_ TOPO.MXD 03125120 

Legend 

D Transloading Facility -Pipeline Alignment

4,000 - -- -0 

� 

TETRA TECH 

PROJECT LOCATION (USGS)

 APPALACHIAN NGL HUB RAIL TRANSLOADING FACILITY 

MONROE COUNTY, OHIO

DRAWN BY: M. SCOTT 03/25/20 

CHECKED BY: L. DRANE 03/25/20 

UPDATED BY: L. DRANE 08/05/20

CONTRACT NUMBER:212C-CF-0026 

FIGURE NUMBER REV 

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Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

2. STUDY AREA 

The Study Area for the Project is located in the Ohio River Valley and starts along the Ohio River 

in Marshall County, West Virginia, crosses under the Ohio River into Monroe County, Ohio (Figure 

2). The Project begins in an industrial area on the east side of the Ohio River in West Virginia. 

After it crosses the Ohio River, the approximately 5.9-mile corridor crosses several ridge and 

valleys as it meanders southward. Except for the beginning and the end of the linear portion 

which are in industrial areas, the majority of the linear portion is a mixture of wooded areas, 

agricultural fields, and rural residential. The elevation along the linear portion ranges from 

approximately 650 feet above mean sea level (ft-amsl) at the beginning in West Virginia up to 

approximately 1350 ft-amsl at the highest ridge point. The Project terminates in a former industrial 

facility that is currently be redeveloped and is located along the western bank of the Ohio River. 

Overall, the Study area is rural and industrial. 
PGH X:IGIS\LONG RIDGE ENERGY\212C-CF-00264 - LONG RIDGE ENERGY TERMINAL TRANSLOADING\NEW FIGS\1.3.1_REPORT_ TERMS1 .MXD 03/27/20 

-NGL Pipeline/Pump Area -Limit of Disturbance (LOO)

NGL Right-of-Way (ROW)

Study Area

D Transloading Facility 

LRET Property 

4,000 - -- -0 

� 

TETRA TECH 

DESCRIPTION OF REPORT TERMS 

APPALACHIAN NGL HUB RAIL TRANSLOADING FACILITY

MONROE COUNTY, OHIO 

DRAWN BY: M. SCOTT 03/23/20 

CHECKED BY: L. DRANE 03/27/20 

UPDATED BY: L. DRANE 08/05/20

CONTRACT NUMBER:212C-CF-0026 

FIGURE NUMBER REV 

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Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

3. PURPOSE AND NEED STATEMENT 

The purpose of the Project is to allow for the safe and efficient movement of NGL’s from the region 

in commercial quantities to east coast markets by using existing rail networks in proximity to 

processing facilities. The Project is needed to address the demand for increased rail capacity to 

allow for expanded NGL distribution from the region. 

The Marcellus and Utica Shale of the Appalachian Basin is one of the largest gas fields in world. 

According to data provided through the Energy and Information Administration (EIA, 2020), 

natural gas production has increased over 84 percent since 2015, and continues to increase. As 

of January 2020, natural gas from the Appalachian Basin accounted for 39 percent of US natural 

gas production. The challenge of moving natural gas and NGLs from the rural areas of 

Appalachia, such as eastern Ohio and West Virginia’s Northern Panhandle, is complex. Pipeline 

capacity has not kept up with demand. While there are pipeline projects planned, they are difficult 

to permit and slow to come online. Another challenge is that NGL facilities have limited rail 

capacity to move energy products. Furthermore, the existing regional fractionation facilities 

cannot meet the current and growing processing demand for NGL constituents such as ethane, 

butane and propane. 

The US Department of Energy (DOE) Primer published June 27, 2018, projects that Appalachian 

NGL products will increase over 700 percent from 2013 to 2023 (US DOE 2018) and states that 

rail capacity is critical “as produced volumes do not align with the high seasonal variability in 

demand and often exceed pipeline takeaway capacity.” If no new alternatives are constructed to 

move NGLs, then the fuel becomes stranded. Rail transportation can expand NGL distribution 

capabilities, allowing NGLs to be delivered directly to end users in a safe and reliable manner. 

Considering the location of the LRET, the access to rail infrastructure and the availability of NGLs 

from the area make this a good location for this type of development and enhanced infrastructure. 

 
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Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

4. ALTERNATIVES 

LRET conducted a preliminary alternatives analysis as part of early planning work to determine 

options for locations for the Transload Facility and the NGL Pipeline. LRET evaluated two layout 

options for the Transloading Facility and four alignments for the NGL Pipeline prior to the EA 

process as part of this early planning work. LRET used evaluation criteria, as shown in Section 

2.1 of the EA, to examine potential impacts of the options. After this preliminary alternative 

analysis, options were dismissed based on the evaluation criteria. The evaluated alternative in 

the EA (the Build Alternative), was the result of the application of the evaluation criteria. 

4.1 No Action Alternative

Transloading Facility 

Under the No Action Alternative, the Transloading Facility will not be constructed. Export potential 

of large volumes of NGL and constituent products will be inhibited and unable to come to market. 

This could cause a delay of extraction of resources that could make it difficult in industry 

expansion and the economic health of rural areas of eastern Ohio and Northern West Virginia. 

Under the No Action Alternative, the local rail infrastructure will not be improved to load and 

transport NGLs from the region, bringing construction and operations jobs. New businesses 

looking to capitalize on the planned infrastructure improvements would seek alternative locations. 

No new jobs will be created and there will be no economic benefit to rural communities in eastern 

Ohio and Northern West Virginia. 

NGL Pipeline 

Under the No Action Alternative, the NGL Pipeline will not be constructed as it is dependent on 

the construction of the Transloading Facility to move NGL by rail. The No Action Alternative will 

not allow a safe and efficient method for transporting the NGLs from the Blue Racer facility; 

therefore, there will be no product available to load at the Transloading Facility. The Blue Racer 

facility is the closest producer of NGLs and other facilities in the region, and without the proposed 

NGL Pipeline and Transloading Facility, an extensive pipeline will be required to transport the 

NGLs to another Transloading Facility or market. 

4.2 Build Alternative (Preferred Alternative) 

As discussed in Section 2.2 of the EA, LRET considered and dismissed several alternatives for 

the Transloading Facility and the NGL Pipeline. Alternative 2 for the Transloading Facility and 

Alternative D for the NGL Pipeline were carried forward for evaluation in the EA and constitute 

the Build Alternative. FRA reviewed the Build Alternative and finds that it meets the purpose and 

need of the Project. Figures 3 and 4 illustrate the Build Alternative. 

Transloading Facility 

The Build Alternative includes a 17-acre site that is located on the LRET Property. New rail spurs 

will extend from the existing spurs to the west of the proposed Transloading Facility. The 

Transloading Facility will be located in the vicinity of the main rail line which will reduce the amount 

of new track needed for the project. The Build Alternative includes time saving steps to efficiently 
FIGURE 3
FIGURE 4
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Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

fill the tank cars by providing on-site storage to help buffer and speed up the rail car loading, from 

which rail cars can be loaded concurrently as NGL is pumped via pipeline from the Blue Racer 

facility. The tank farm includes six 60,000 gallon propane tanks (total storage capacity of 360,000-

gallons), six 60,000 gallon butane tanks (total of 360,000-gallons of storage capacity), and a 

630,000 gallon condensate/natural gasoline tank. The respective NGL products will be loaded 

into the rail cars through pipe racks that will be situated between the rail spurs. As NGL fuel types 

are switched in the NGL pipeline a commixture of residual product remains and mixes with the 

initial slug new fuel type. This commixture will be sent to a transmix tank and the commixture of 

products will be sent back to the Blue Racer facility for reprocessing. Off-gas materials will be 

burnt through enclosed ground flares. 

NGL Pipeline 

The Build Alternative includes the construction of a new pipeline from the Blue Racer facility to 

the proposed Transloading Facility. This approximately 5.9-mile 10-inch pipeline will originate at 

the Blue Racer facility and cross the Ohio River using an Horizontal Directional Drill (HDD) bore. 

New pumps will be installed at the Blue Racer facility to pump the NGLs through the NGL Pipeline 

to the Transloading Facility. One interconnect valve will be above ground, located on the western 

side of the Ohio River near the HDD bore exit point. This interconnect valve will be within the 

NGL Pipeline right-of-way (ROW). 

The bore will extend the highlands to the west of the Ohio River in Ohio and the pipeline 

route will continue underground to the south-southeast into the proposed Transloading 

Facility. The proposed location of the pipeline route was selected to reduce impacts to 

natural resources. The southern portion of the route is situated so that it takes advantage of 

an existing pipeline ROW. 

 
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Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

5. SELECTED ALTERNATIVE 

The Selected Alternative consists of the Build Alternative evaluated in the EA. It best meets the 

purpose and need of the project. The Selected Alternative was the only build alternative carried 

forward for further analysis in Section 2.3 of the EA. The No Action Alternative was evaluated as 

further described in Section 2.3.1 as a basis against which to compare the Build Alternative in 

evaluation of environmental impacts but was not identified as the Selected Alternative because it 

did not meet the Project purpose and need. 

The Selected Alternative provides a number of benefits, including: 

 Creating a time savings from efficiently filling tank cars from on-site storage, which speeds 

up rail car loading as rail cars can be loaded concurrently with NGL pumping from Blue 

Racer. 

 Providing additional capacity for moving NGL from the region. 

 Beneficial impact on socioeconomic resources due to access to both short-term 

construction jobs and permanent jobs at the Transloading Facility. 

 

Based upon the EA, incorporated by reference with its appendices in this FONSI in its entirety, 

FRA has concluded that the Selected Alternative will have no foreseeable significant impact on 

the quality of the natural and human environments. The Selected Alternative is best able to 

achieve the proposed action purpose and need without significant environmental impacts. 

Minimization and mitigation measures were included in the EA to further reduce environmental 

impacts, and even without these measures, the environmental impacts would not rise to a level 

of significance. 

 
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Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

6. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENSES 

The EA describes the existing conditions in the study area and the potential impacts that would 

result if the Selected Alternative is implemented. Information was gathered from various 

sources, including site observations, maps, aerial photography, and local state and federal 

agency data. 

Table 1 summarizes the physical, biological, and human resources detailed in the EA and the 

applicable Mitigation Measures. 
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Finding of No Significant Impact

Appalachian NGL HUB Rail Transloading Facility

August 2020

Table 1 

Summary of Environmental Consequences and Minimization Measures 

Environmental Resource Environmental Consequences Mitigation Measures 

Geological/Physical Setting 

(3.1) 

No impacts to geological resources are anticipated 

with the Transloading Facility. 

GEO-01: LRET will conduct geotechnical studies to 

determine the underlying soil bearing capacities and 

foundation design. 

The NGL Pipeline route was selected to minimize 

encountering side-slopes and deep narrow stream 

valleys. When steeper slopes are encountered, 

the NGL Pipeline route would be orientated so that 

it runs perpendicular to the contour to the extent 

possible. Small slides could occur in steeper areas 

and in areas of water saturated soils. 

GEO-02: As required under the Ohio Linear Pipeline 

Construction Stormwater permit and Ohio Revised Code 

(ORC) 6111, LRET will return the grade along the 

pipeline route to pre-construction conditions. Returning 

the grade to its preconstruction contours will minimize the 

potential for landslides and slope failures. 

During advancement of the HDD bore through the 

bedrock, fractures may be encountered, and some 

minor drilling mud loss would be expected within 

those fractures. The NGL Pipeline could result in 

negative impacts through inadvertent return of 

drilling mud to the surface water. 

GEO-03: In accordance with permit for WV 401 WQC, 

LRET will develop an Inadvertent Return Contingency 

Plan (IRCP), with contingencies for loss of drilling mud in 

bedrock fractures. The plan will include monitoring 

procedures to be implemented during drilling and action 

plans in the event of inadvertent returns. 

Groundwater Hydrology/Water 

Resources (3.2) 

Potential for adverse impact to groundwater 

resources in the event of an unmanaged spill or 

release during construction or operation. 

GHYD-01: LRET will develop and implement a 

Stormwater Pollution Prevention Plan (SWPPP) in 

accordance with the Ohio Construction Stormwater 

permit and the ORC 6111. This SWPPP will include best 

management practices (BMPs) that will specifically 

include dust suppression techniques. 

Potential impacts from spills at the Transloading 

Facility stem from the use of petroleum products 

for equipment operation and hazardous materials 

used during construction, which could contaminate 

the groundwater. 

GHYD-02: LRET will prepare a spill prevention control 

and countermeasure (SPCC) plan in accordance with 40 

CFR 112, Subpart A. This plan will cover all petroleum 

products that will be stored on the facility and include 

plans for emergency response in the event of a release. 
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Finding of No Significant Impact

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August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

During advancement of the HDD bore, drilling mud 

could be lost in the geologic formations that exhibit 

significant fractures. The inadvertent return of 

drilling mud into the geologic formations would 

raise the turbidity of the groundwater in the vicinity 

of the bore. 

 

GEO-03: In accordance with permit for WV 401 WQC, 

LRET will develop an Inadvertent Return Contingency 

Plan (IRCP), with contingencies for loss of drilling mud in 

bedrock fractures. The plan will include monitoring 

procedures to be implemented during drilling and action 

plans in the event of inadvertent returns. 

HAZ-01: LRET will prepare a Soil Management Plan to 

address encountering contaminated soils. This plan will 

include soil screening requirements, the oversight or 

monitoring of soil moving activities by an environmental 

professional, and contingency plans for the handling, 

removing, temporarily storing, characterizing, and 

disposing of contaminated materials. This plan will also 

include measures for containing, treating, and disposing 

of stormwater that may contact exposed soils. 

PH-03: Emergency response procedures will be 

developed by LRET for operation of the pipeline to 

evacuate any residual materials from that segment of the 

pipeline to keep them from entering the environment, as 

mentioned in Section 3.11.3 of the EA. In the event of a 

release of NGL to the environment, LRET will implement 

a specific notification program, including notifications to 

the appropriate emergency response agencies, 

potentially impacted residents, and regulatory agencies. 

Surface Hydrology/Floodplains 

(3.3) 

During construction, surface water runoff in contact 

with exposed soil would have elevated turbidity and 

would require treatment prior to discharge. 

SHYD-01: LRET will prepare a post-construction 

stormwater management (PCSM) plan based on the final 

design and layout. The PCSM plan will include 

stormwater detention basins and feed the existing 

stormwater control system at the LRET Property. 

Several streams would be crossed and temporarily 

impacted for installation of the NGL Pipeline. 

SHYD-02: LRET will restore impacted streams to 

preconstruction conditions upon completion of the 

pipeline installation in accordance with necessary 

conditions of applicable US Army Corps of Engineers 

Nationwide-12/Individual Permit 404 Permit and the Ohio 

EPA 401 Water Quality Certification. 
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Finding of No Significant Impact

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August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

GEO-02: As required under the Ohio Linear Pipeline 

Construction Stormwater permit and Ohio Revised Code 

(ORC) 6111, LRET will return the grade along the 

pipeline route to pre-construction conditions. Returning 

the grade to its preconstruction contours will minimize the 

potential for landslides and slope failures. 

GHYD-01: LRET will develop and implement a 

Stormwater Pollution Prevention Plan (SWPPP) in 

accordance with the Ohio Construction Stormwater 

permit and the ORC 6111. This SWPPP will include best 

management practices (BMPs) that will specifically 

include dust suppression techniques. 

Aquatic Resources (3.4) 

The four wetlands in the Study Area for the 

Transloading Facility are outside of the 

construction area. 

AQUA-01: In accordance with the Ohio Linear Pipeline 

Construction Stormwater permit, NWP 12, Section 10, 

and Ohio EPA 401 WQC, a detailed Erosion and 

Sediment Control Plan (ESCP) will be developed by 

LRET prior to initiating construction. LRET will install silt 

fence at the edge of work areas, as necessary, to prevent 

movement of silt into wetlands. The fencing will be 

maintained throughout construction until final site 

stabilization is achieved. LRET will clearly mark wetland 

boundaries prior to construction activities. LRET will 

develop procedures for appropriate dewatering and 

discharge, including measures to limit erosive forces. 

During advancement of the HDD bore required for 

the crossing of the Ohio River, drilling mud could 

be lost in the geologic formations that exhibit 

significant fractures. The inadvertent return of 

drilling mud into the geologic formations would 

raise the turbidity of the groundwater in the vicinity 

of the bore. 

GEO-03: In accordance with permit for WV 401 WQC, 

LRET will develop an Inadvertent Return Contingency 

Plan (IRCP), with contingencies for loss of drilling mud in 

bedrock fractures. The plan will include monitoring 

procedures to be implemented during drilling and action 

plans in the event of inadvertent returns. 
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Finding of No Significant Impact

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August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

There will be temporary impacts to wetlands and 

streams for construction of the NGL Pipeline. 

These impacts will occur as a result of in-stream 

construction activities, minor earth disturbances 

within the stream floodways, or construction on 

slopes adjacent to stream channels. These 

activities could result in a temporary localized 

increase in turbidity levels and downstream 

sediment deposition. Permanent impacts to water 

quantity and flow rates are not anticipated, and 

hydrologic conditions are not anticipated to be 

impacted. 

AQUA-02: In accordance with the Ohio Linear Pipeline 

Construction Stormwater permit, NWP 12, Section 10, 

and Ohio EPA 401 WQC, LRET commits to Restoration 

and Revegetation occurring. LRET will restore areas 

temporarily impacted by Project construction to 

preconstruction contours. LRET will revegetate cleared 

areas as soon as practicable following completion of 

construction to stabilize exposed areas of soil. Species 

proposed for the seeding will be selected to ensure 

compatibility and suitability with surrounding agricultural 

areas and measures will be instituted to prevent the 

spread of invasive species through revegetation with 

native plant species. 

AQUA-03: Stream Crossing Impact Minimization: LRET 

will install the NGL Pipeline using techniques to minimize 

construction-related impacts to surface waters. LRET will 

comply with permit conditions, and implement BMPs that 

will avoid or minimize adverse impacts on fish and other 

aquatic organisms. 
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Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

Where practicable, routing was adjusted to avoid 

aquatic resources. LRET anticipates that all 

wetland crossings would meet the conditions of 

and be authorized under USACE NWP 12. BMPs 

(detailed in EA Section 3.4.3) implemented in the 

NGL Pipeline routing and design phase were used 

to minimize impacts to aquatic resources. 

AQUA-02: In accordance with the Ohio Linear Pipeline 

Construction Stormwater permit, NWP 12, Section 10, 

and Ohio EPA 401 WQC, LRET commits to Restoration 

and Revegetation occurring. LRET will restore areas 

temporarily impacted by Project construction to 

preconstruction contours. LRET will revegetate cleared 

areas as soon as practicable following completion of 

construction to stabilize exposed areas of soil. Species 

proposed for the seeding will be selected to ensure 

compatibility and suitability with surrounding agricultural 

areas and measures will be instituted to prevent the 

spread of invasive species through revegetation with 

native plant species. 

AQUA-03: Stream Crossing Impact Minimization: LRET 

will install the NGL Pipeline using techniques to minimize 

construction-related impacts to surface waters. LRET will 

comply with permit conditions, and implement BMPs that 

will avoid or minimize adverse impacts on fish and other 

aquatic organisms. 

A portion of one forested wetland will be converted 

to an emergent wetland. 

AQUA-04: Wetland and stream impacts will be subject to 

state and federal permitting requirements. LRET will 

comply with approved wetland off-set measures or 

compensation for the conversion of forested wetlands to 

emergent wetlands, such as restoration, creation, 

enhancement and/or preservation of wetlands. 

Threatened and Endangered 

Species (3.5) 

There are some isolated trees that may require 

removal at the proposed Transloading Facility and 

approximately 21 acres of tree clearing required for 

the NGL Pipeline. With the measures outlined in 

EA Section 3.5.3, FRA determined that 

construction of the Project is “not likely to adversely 

affect” the Indiana bat or northern long-eared bat. 

FRA also determined the Project would have “no 

effect” on other federally listed species. The 

USFWS Ohio Field Office concurred with this 

finding in a letter dated March 13, 2020. 

T&E-01: Tree clearing will be conducted by LRET 

between October 1st and March 31st. There will be no 

tree clearing between April 1 and September 30. 
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Finding of No Significant Impact

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August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

The FRA also determined there would be “no 

effect” on federally listed species at the origination 

of the NGL Pipeline at the Blue Racer facility and 

the associated HDD in West Virginia. The USFWS 

West Virginia field office concurred with this finding 

in writing on January 14, 2020. 

T&E-02: If any tree clearing will be required outside of 

the time period in T&E-01, a presence/absence survey 

may be required. LRET will inform FRA, and further 

coordination will be conducted with USFWS Ohio Field 

Office and ODNR. 

The Ohio River and Opossum Creek crossings 

would be accomplished via HDD and conventional 

bore, respectively; therefore, LRET does not 

anticipate any impacts to state-listed aquatic 

species at these crossings. The proposed 

conventional bore crossing of Opossum Creek and 

avoidance of stream impacts would address the 

ODNR recommendation for a freshwater mussel 

survey at this crossing. The ODNR does not 

anticipate any impacts to the eastern hellbender 

from the proposed Project due to the proposed 

Project location and lack of suitable potential 

habitat. 

 

T&E-03: To avoid impacts to state-listed aquatic species, 

LRET will conduct in-stream work within perennial 

streams outside of the ODNR recommended TOYR (April 

15 – June 30). There will be no in-stream work within 

perennial streams between April 15 and June 30. 

T&E-04: To minimize potential stream and associated 

species impacts, LRET will construct the pipeline at the 

two largest water body crossings (Ohio River and 

Opossum Creek) via HDD and conventional bore, 

respectively. 

Historic Properties (3.6) 

The FRA determined the construction and 

installation associated with the Transloading 

Facility would have No Effect on historic properties. 

The Ohio Historic Preservation Office (OHPO) 

concurred with this finding. 

None identified. 

 

 

 

The West Virginia Division of Culture and History 

(WVDCH) commented on the Project on January 9, 

2020, concurring with FRA’s determination that no 

archaeological investigations were necessary and 

that there would be No Effect to historic properties. 
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Finding of No Significant Impact

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August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

FRA completed survey work of the Area of 

Potential Effects (APE) for the NGL Pipeline 

component for both archaeology and built 

environment. Archaeological survey work 

identified one historic archaeological resource that 

FRA determined was ineligible for listing in the 

National Register of Historic Places (NRHP). The 

built environment survey work identified five 

potentially-eligible resources; two of these 

resources were determined eligible for the NRHP, 

the Lucas Farmstead and the Rufener Farmstead. 

FRA determined that the impacts to these 

properties from the Project would not diminish the 

historic integrity of the properties. Therefore, FRA 

determined the Project would have No Adverse 

Effect on historic properties. The OHPO concurred 

with this finding. 

FRA sent consultation packages to the following 

federally-recognized tribes: Eastern Shawnee Tribe 

of Oklahoma, Miami Tribe of Oklahoma, Osage 

Nation, and Seneca Cayuga Nation. The Miami 

Tribe of Oklahoma responded stating that Monroe 

County was not in their area of concern. No other 

responses from tribes were received. Additional 

details of tribal consultation are discussed in 

Section 8.1 of this FONSI below. 
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Finding of No Significant Impact

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August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

Contaminated Sites and 

Hazardous Waste (3.7) 

With the current groundwater restrictions, cover 

systems, interceptor wells, in addition to 

operational Ranney wells, the contamination found 

to the east and southeast (downgradient) of the 

Transloading Facility is not expected to enter the 

proposed Transloading Facility. However, based 

on historical use of the LRET Property there is a 

slight potential that contaminated soils could be 

encountered during earthwork activities and site 

grading. Groundwater is not anticipated to be 

directly encountered during earthwork or grading. 

If contaminated soils were encountered and 

exposed to precipitation, contaminants could filter 

into the groundwater. 

HAZ-01: LRET will prepare a Soil Management Plan to 

address encountering contaminated soils. This plan will 

include soil screening requirements, the oversight or 

monitoring of soil moving activities by an environmental 

professional, and contingency plans for the handling, 

removing, temporarily storing, characterizing, and 

disposing of contaminated materials. This plan will also 

include measures for containing, treating, and disposing 

of stormwater that may contact exposed soils. 

Contamination from down gradient sites would 

likely not be encountered during construction of the 

NGL Pipeline. However, based on the historical 

and current industrial use of the Blue Race facility 

and the LRET Property, and the overlap of the 

NGL Pipeline where it connects with existing 

facilities, there is a slight potential that 

contaminated soils could be found during 

earthwork activities, site grading, and installation of 

the HDD bore. 

HAZ-02: LRET will prepare a Groundwater Management 

Plan to address the unlikely event of encountering 

contaminated groundwater from known down gradient 

sites. This plan will include the oversight of soil moving 

activities by an environmental professional, groundwater 

screening procedures, handling, temporary storage, 

characterization, and disposal of contaminated 

groundwater. This plan will also include contingencies 

for collecting, stabilizing, and disposal of drilling mud that 

may be exposed to contaminated groundwater. 

Air Quality and Greenhouse 

Gas Emissions (3.8) 

The Transloading Facility will have potential NOx, 

CO, and VOC emissions that exceed the minor 

source air permitting thresholds and, therefore, 

would require a permit to construct and a permit to 

operate in accordance with the Ohio Administrative 

Code (OAC) chapter 3745-31. 

AQ-01: LRET will use best available techniques (BAT) 

emission controls, including the flare and thermal 

combustor to control organic vapor emissions during 

railcar loading. LRET will also comply with requirements 

in applicable New Source Performance Standards 

(NSPS) and the conditions contained in the Ohio EPA Air 

Permit to construct and operate the Project. 
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Finding of No Significant Impact

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August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

The GHGs produced by the Project are CO2, CH4, 

and N2O during operation; hydrofluorocarbons, 

perfluorocarbons, and sulfur hexafluoride will not 

be emitted by the Project. 

AQ-02: LRET will limit full-capacity flare operation during 

railcar loading conditions (with pilot operation occurring 

otherwise) and minimize idling emissions from 

locomotives. 

The Project will result in air pollutant emissions 

during short-term construction activities of the 

Transloading Facility. Emissions associated with 

construction activities generally include fugitive 

dust from soil disruption and combustion emissions 

from construction equipment. 

AQ-03: LRET will use dust suppression techniques in 

sensitive areas to mitigate fugitive particulate matter from 

construction activities. 

The Project will result in air pollutant emissions 

during short-term construction activities of the NGL 

Pipeline. 

Because the NGL Pipeline includes no fuel 

combustion or chemical processes, it is not 

expected to result in operational emissions. 

 
21 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

Noise and Vibration (3.9) 

Table 3.9.2 of the EA summarizes the predicted 

noise levels for each construction phase of the 

Transloading Facility. Construction sound levels 

do not exceed the Federal Transit Administration 

(FTA) construction impact guidelines at any of the 

monitoring locations. Based on FTA guidelines, 

the noise levels resulting from the operation of the 

proposed Transloading Facility would be 

considered as “no impact” and mitigation is not 

required. 

N&V-01: LRET will implement construction management 

procedures, which are best management practices, for 

both the Transloading Facility and the NGL Pipeline and 

include the following noise mitigation measures to 

minimize noise impacts: 

• Maintain all construction tools and equipment in good 

operating order according to manufacturers’ 

specifications; 

• Limit use of major excavating and earth moving 

machinery to daytime hours; 

• To the extent practicable, schedule construction activity 

during normal working hours on weekdays when higher 

sound levels are typically present; 

• Equip any internal combustion engine used for any 

purpose on the job or related to the job with a properly 

operating muffler that is free from rust, holes, and leaks; 

• For construction devices that use internal combustion 

engines, ensure the engine’s housing doors are kept 

closed, and install noise-insulating material mounted on 

the engine housing consistent with manufacturers’ 

guidelines, if possible; 

• Limit possible evening shift work to low noise activities 

such as welding, wire pulling and other similar activities, 

together with appropriate material handling equipment; 

• Use a Complaint Resolution Procedure to address any 

noise complaints received from residents; and 

• Communicate with neighbors prior to conducting 

specific loud noise activities such as steam blows. 
22 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

Based on the calculated vibration levels for the 

Transloading Facility, damage to structures could 

occur within 25 feet from the source and human 

annoyance could occur within 50 feet from the 

source. There are no sensitive receptors located 

50 feet or less from the earth moving equipment. 

Therefore, vibration impacts due to construction 

are unlikely to occur. Transloading Facility 

operational vibration levels will be below the 80 

VdB nighttime standards at the nearest residences. 

 

There are residences within the vicinity of the NGL 

Pipeline limits of disturbance (LOD), with the 

closest residence being 200 feet from the NGL 

Pipeline LOD. Given the proximity of these 

residences to the NGL Pipeline LOD, there will be 

noise impacts associated with construction of the 

NGL Pipeline. There will be no noise impacts 

associated with the operation of the NGL Pipeline. 

N&V-02: Specific to the NGL Pipeline near residences, 

LRET will work with the property owners on noise 

reduction measures. The majority of NGL Pipeline 

construction will occur during regular daylight hours. If 

any night time work is required, LRET will notify 

residents. 

Based on FTA guidelines, there will be no vibration 

impacts beyond 25 ft during typical construction 

activities within the NGL Pipeline LOD, and no 

vibration impacts beyond 100 ft during HDD drilling 

unless there is rock blasting. There are no 

sensitive receptors located within these distances 

and there is currently no rock blasting anticipated 

during the project. There will be no vibration 

impacts associated with the operation of the NGL 

Pipeline. 

Land Use, Planning, and 

Property Acquisitions (3.10) 

The property where the proposed Transloading 

Facility will be constructed is owned by the parent 

company of LRET and no property acquisition 

would be required for building the Transloading 

Facility. 
23 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

No change in land use is expected to occur under 

development of the NGL Pipeline. Approximately 

21 acres of wooded area will be cleared for 

construction of the NGL Pipeline between the Ohio 

River and Transloading Facility. No trees would be 

permitted to grow over the NGL Pipeline ROW. No 

property is expected to be purchased for 

development of the NGL Pipeline. Lease or 

easement agreements would be negotiated with 

each of the individual property owners. 

LAND-01: After construction, LRET will restore the LOD 

for the NGL Pipeline to as near as previous condition as 

possible, with the exception of former wooded areas 

which will be permanently converted to meadow. 

While there will be temporary impacts to property 

owners, the NGL Pipeline will not result in a long 

term impacts to property uses along the LOD. 

Property owners will have restive use of the ROW 

as negotiated in the lease or easement agreement. 

TRSP-01: A road use maintenance agreement (RUMA) 

will be put in place by LRET with Monroe County and the 

Township prior to use of the road or pipeline construction. 

This agreement will include an evaluation of the current 

condition and a requirement to return the road to the 

previous condition (condition prior to the construction 

activities) or better condition. The RUMA will also 

describe any travel restrictions that would occur during 

construction. LRET will implement travel restrictions for 

pipeline construction personnel and related equipment 

deliveries or oversized loads during school bus travel 

times, if applicable. In the event of an emergency, 

response vehicles will be given the priority. The RUMA 

will detail contingencies, notification procedures, and 

emergency procedures related to transportation and 

traffic. LRET will work with Monroe County and the 

school district to get the information on bus routes and 

schedules prior to each school year during the 

construction period. Once the school bus routes and 

schedules are determined, LRET will coordinate with the 

school system prior to construction to be able to work 

around those schedules, if needed. This information will 

be detailed in the RUMA. 
24 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

Parks, Recreation Areas, and 

Section 4(f) (3.11) 

The Transloading Facility will be constructed on a 

portion of the former industrial facility within LRET 

Property, which is privately owned and operated. 

There are no parks, designated recreation areas or 

Section 4(f) resources within 1-mile of the 

proposed facility; therefore, no impacts to parks, 

recreation areas, or Section 4(f) resources will 

occur. 

PARK-01: In accordance with the WV 401 WQC permit 

and WV 47CSR2, LRET will equip the NGL Pipeline with 

an emergency shut-off that will be located on both sides 

of the Ohio River. If there is a detected drop in pressure 

during pipeline use, such as would result from a leak 

from the pipeline, a valve will be automatically engaged 

to shut down the pipeline and to minimize any potential 

impacts to the environment. Emergency response 

procedures will also be put in place by LRET to evacuate 

any residual materials from that segment of the pipeline 

to keep them from entering the environment. 

The NGL Pipeline will not impact any public parks 

or resources and will not adversely affect any 

historic properties that are protected under Section 

4(f). 

PARK-02: LRET will provide newspaper notices prior to 

construction of the NGL Pipeline to notify users of the 

CONSOL Energy Powhatan Wildlife Agreement Area 

about the planned project and restricted access during 

construction. LRET will provide personnel to monitor the 

LOD during construction to keep the public off the LOD 

for their protection. 

The installation and operation of the NGL Pipeline 

would likely not impede public access or use of the 

Ohio River; although, during the drilling of the HDD 

bore, drilling mud could be lost in fractures. Drilling 

mud lost to fractures could migrate upward into the 

Ohio River affecting the river water quality and 

potentially affecting recreational use of the river for 

a period of time. During operation of the NGL 

Pipeline, there would be the potential for a leak to 

occur from the pipeline, which could migrate 

upward and impact the quality of the water in the 

Ohio River. A significant release could have an 

adverse effect on the water quality restricting 

access to, and use of, the Ohio River for 

recreational purposes. 

GEO-03: In accordance with permit for WV 401 WQC, 

LRET will develop an Inadvertent Return Contingency 

Plan (IRCP), with contingencies for loss of drilling mud in 

bedrock fractures. The plan will include monitoring 

procedures to be implemented during drilling and action 

plans in the event of inadvertent returns. 
25 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

During construction of the NGL Pipeline, the 

portion of the LOD that traverses the CONSOL 

Energy Powhatan Point Wildlife Agreement Area 

would be inaccessible to the public; construction of 

the NGL Pipeline would restrict access to 

approximately 2.4 acres of the approximately 

2,000-acre area. Hunting activities may be 

temporarily impacted depending on the when the 

pipeline is constructed and what hunting seasons 

are within that time period. 

PARK-03: An easement or other arrangement will be 

obtained by LRET from CONSOL Energy to grant access 

for construction and the permanent ROW for the NGL 

Pipeline. 

Public Health, Elderly and 

Persons with Disabilities (3.12) 

Access to the proposed Transloading Facility 

would be from the existing access road for the 

LRET Property, and there would be no significant 

changes to traffic patterns that would impact the 

public, elderly, or persons with disabilities. 

PH-01: LRET will restrict access to the new access road 

created for the NGL Pipeline interconnect valve, as 

indicated with signage near the road entrance. 

The construction of the NGL Pipeline would mostly 

occur in lightly populated areas and would not 

affect the elderly or disabled persons. 

 

PH-02: LRET, in cooperation with Monroe County and 

the Township, will develop a resident coordination and 

communication plan for project road use that instructs 

LRET’s contractor on procedures and required 

notifications when hauling oversized loads that may 

result in restricting public access to roads on a temporary 

basis during construction. LRET will notify the local 

residents of the potential road access restriction and 

oversized loads’ will be coordinated during construction. 
26 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

PH-03: Emergency response procedures will be 

developed by LRET for operation of the pipeline, as 

mentioned in Section 3.11.3 of the EA. In the event of a 

release of NGL to the environment, LRET will implement 

a specific notification program, including notifications to 

the appropriate emergency response agencies, 

potentially impacted residents, and regulatory agencies. 

GHYD-02: LRET will prepare a spill prevention control 

and countermeasure (SPCC) plan in accordance with 40 

CFR 112, Subpart A. This plan will cover all petroleum 

products that will be stored on the facility and include 

plans for emergency response in the event of a release. 

PARK-01: In accordance with the WV 401 WQC permit 

and WV 47CSR2, LRET will equip the NGL Pipeline with 

an emergency shut-off that will be located on both sides 

of the Ohio River. If there is a detected drop in pressure 

during pipeline use, such as would result from a leak 

from the pipeline, a valve will be automatically engaged 

to shut down the pipeline and to minimize any potential 

impacts to the environment. Emergency response 

procedures will also be put in place by LRET to evacuate 

any residual materials from that segment of the pipeline 

to keep them from entering the environment. 
27 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

TRSP-01: A road use maintenance agreement (RUMA) 

will be put in place by LRET with Monroe County and the 

Township prior to use of the road or pipeline construction. 

This agreement will include an evaluation of the current 

condition and a requirement to return the road to the 

previous condition (condition prior to the construction 

activities) or better condition. The RUMA will also 

describe any travel restrictions that would occur during 

construction. LRET will implement travel restrictions for 

pipeline construction personnel and related equipment 

deliveries or oversized loads during school bus travel 

times, if applicable. In the event of an emergency, 

response vehicles will be given the priority. The RUMA 

will detail contingencies, notification procedures, and 

emergency procedures related to transportation and 

traffic. LRET will work with Monroe County and the 

school district to get the information on bus routes and 

schedules prior to each school year during the 

construction period. Once the school bus routes and 

schedules are determined, LRET will coordinate with the 

school system prior to construction to be able to work 

around those schedules, if needed. This information will 

be detailed in the RUMA. 
28 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

Safety and Security (3.13) 

During construction and operation of the proposed 

Transloading Facility, there are no anticipated 

impacts to safety and security as the Transloading 

Facility would be constructed on private property. 

S&S-01: LRET will control and limit access to the 

Transloading Facility to a single entrance with signage 

that makes it clear public access is not permitted. 

Signage would be posted at the entrance, warning of 

hazardous conditions and that only authorized personnel 

will be allowed on the site. Signage indicating “No 

trespassing” will be posted where appropriate. 

During construction of the NGL Pipeline, 

coordination would occur with local security and 

emergency response personnel, as the LOD for the 

NGL Pipeline would be restricted from public 

access during the construction activities. Access 

to the NGL Pipeline would be restricted to 

individual property owners, as the ROW is located 

on private property. Portions of the property that 

are open for public hunting and use would be 

returned to normal access once the NGL Pipeline 

is completed. 

S&S-02: LRET will provide security personnel to monitor 

the NGL Pipeline LOD during construction to keep the 

public off the LOD and safe from the construction 

activities. Marking of the pipeline will be in accordance 

with ORC 4901:1-16, 49 C.F.R. 40, 49 C.F.R. 191, 49 

C.F.R. 192 and 49 C.F.R. 199. As stated in 49 C.F.R. 

192, the marker warning must consist of the following 

written legibly on the background of a sharply contrasting 

color on each line marker: the word “Warning”, “Caution”, 

or “Danger”, followed by the words “Gas (or name of gas 

transported) Pipeline”, all of which, except for markers in 

heavily developed urban areas, must be in letters at least 

1 inch (25 millimeters) high with 1⁄4 inch (6.4 millimeters) 

stroke. The name of the operator and telephone number 

where the operator can be reached at all times should 

also be present. 
29 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

Environmental Justice (3.14) 

Based on the demographic profile of Monroe 

County, Ohio and the Marshall County, West 

Virginia, neither the Transloading Facility nor the 

NGL Pipeline would present a disproportionate 

impact on minority or low-income populations 

because of the limited populations present within 

these areas and because the Project will not cause 

adverse impacts to resources related to 

environmental justice. 

None identified. 

Socioeconomic Resources 

(3.15) 

The proposed Transloading Facility would be 

constructed on the LRET property. The Proposed 

Action would bring an economic benefit to the 

region. Jobs would be created by providing 

additional capacity for moving NGL from the 

region, and also during construction and operation 

of the facility. 

None identified. 

 

The NGL Pipeline would not impact the population 

of Monroe County, Ohio and Marshall County, 

West Virginia. During construction of the NGL 

Pipeline, construction jobs would be available 

including labor, equipment operators, pipefitters, 

welders, environmental inspectors, construction 

management, truck driving, and drilling operators. 

The project would be a beneficial impact on 

socioeconomic resources. 

Energy Use (3.16) 

Under the Proposed Action Alternative, the 

temporary draw on the local power supply would 

be increased but would not result in an interruption 

of service or undue stress on the existing electrical 

infrastructure. No impacts are anticipated 

stemming from the construction and operation of 

the proposed Transloading Facility. 

None identified. 

 
30 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

During construction of the proposed NGL Pipeline, 

electrical needs would be supplied through 

portable generators as needed for lighting, running 

pumps, welding, tools, etc. The electrical power 

needed to construct and install the remainder of 

the NGL Pipeline in Monroe County, Ohio, would 

be provided by portable power generation units 

that would not draw on the existing electrical grid. 

Aesthetics and Visual Quality 

(3.17) 

The visual effects of the Transloading Facility 

would be minimal. 

None identified. 

The NGL Pipeline would traverse rural areas, 

mostly farm fields and wooded areas. The NGL 

Pipeline would be buried, so once the NGL 

Pipeline is installed, there would be no significant 

changes to the viewshed except where trees would 

be removed for construction and continued 

maintenance of the pipeline. 

None identified. 
31 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

Transportation Resources 

(3.18) 

During the operation of the proposed Transload 

Facility, vehicular traffic would see a minor 

increase from the addition of eight new full-time 

employees and occasional delivery trucks that 

would enter the Transloading Facility for collecting 

transmix NGL. Rail traffic to the proposed 

Transloading facility would increase and the facility 

is expected to fill 40-rail cars at a time. Based on 

the minimal increase of traffic during construction 

and the rail storage capacity at the LRET Property, 

the Transloading Facility would not have impacts 

on transportation resources. 

TRSP-01: A road use maintenance agreement (RUMA) 

will be put in place by LRET with Monroe County and the 

Township prior to use of the road or pipeline construction. 

This agreement will include an evaluation of the current 

condition and a requirement to return the road to the 

previous condition (condition prior to the construction 

activities) or better condition. The RUMA will also 

describe any travel restrictions that would occur during 

construction. LRET will implement travel restrictions for 

pipeline construction personnel and related equipment 

deliveries or oversized loads during school bus travel 

times, if applicable. In the event of an emergency, 

response vehicles will be given the priority. The RUMA 

will detail contingencies, notification procedures, and 

emergency procedures related to transportation and 

traffic. LRET will work with Monroe County and the 

school district to get the information on bus routes and 

schedules prior to each school year during the 

construction period. Once the school bus routes and 

schedules are determined, LRET will coordinate with the 

school system prior to construction to be able to work 

around those schedules, if needed. This information will 

be detailed in the RUMA. 

As discussed in Section 3.12 and 3.13 of the EA, 

during the construction and installation of the 

pipeline, local roads would be used to access the 

pipeline route and work areas associated with the 

pipeline. Once the NGL Pipeline has been installed 

and the area has been restored, there would be no 

additional traffic for the NGL Pipeline. 

PH-01: LRET will restrict access to the new access road 

created for the NGL Pipeline interconnect valve, as 

indicated with signage near the road entrance. 
32 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Environmental Resource Environmental Consequences Mitigation Measures 

 PH-02: LRET, in cooperation with Monroe County and 

the Township, will develop a resident coordination and 

communication plan for project road use that instructs 

LRET’s contractor on procedures and required 

notifications when hauling oversized loads that may 

result in restricting public access to roads on a temporary 

basis during construction. LRET will notify the local 

residents of the potential road access restriction and 

oversized loads’ will be coordinated during construction. 

Indirect and Cumulative 

Impacts (3.19) 

The planned capacity for the Transloading Facility 

would be sufficient for the reasonably foreseeable 

future. The usage of existing capacity and 

expanded services of the Transloading Facility 

could result in additional jobs to individuals in 

Monroe County through temporary construction 

jobs and additional operational jobs relating to the 

production and shipping of other petroleum 

products in the region. While such development is 

possible, there are no known plans for it and as 

such any discussion of potential impacts would be 

speculative. 

None identified. 

Except for adverse effects from an unexpected 

leak or release from the pipeline, which are 

considered and addressed in Section 3.12 and 

3.12 of the EA, there would be no anticipated 

indirect impacts to human health or individuals as a 

result of the NGL Pipeline. 
33 | Page

Finding of No Significant Impact

Appalachian NGL HUB Rail Transloading Facility

August 2020

7. MITIGATION MEASURES 

Monroe County and LRET are required to comply with all applicable federal, state, and local 

permitting requirements during the implementation of the Selected Alternative, which include: 

 Federally Funded Transloading Facility 

o Local Fire Jurisdiction/Ohio Department of Commerce 

o Ohio Building Code, Department of Commerce 

o Ohio Environmental Protection Agency (EPA) Air Permit 

o Ohio EPA Construction Stormwater Permit 

o Ohio EPA Hydrostatic Test Discharge National Pollutant Discharge Elimination 

System (NPDES) 

o Ohio EPA NPDES Permit 

 Non-Federally Funded NGL Pipeline 

o USACE Nationwide Permit (NWP)-12 

o USACE Section 10 Authorization 

o Ohio EPA Hydrostatic Test Discharge NPDES 

o Ohio Linear Pipeline Construction Stormwater 

o Ohio EPA 401 WQC 

o West Virginia (WV) 401 WQC 

o West Virginia Construction Stormwater 

o West Virginia Hydrostatic Test Discharge NPDES 

The mitigation measures shown in Table 1 have been identified to address and further reduce 

impacts of the Project. As the grantee, Monroe County is ultimately responsible for ensuring 

all environmental commitments identified in this FONSI are implemented, including those 

mitigation measures identified in Table 1 that will be directly implemented by LRET. 

 
34 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

8. COORDINATION AND CONSULTATION 

This section describes coordination and consultation efforts that occurred during the evaluation 

of the Project. Coordination and consultation efforts focused on potential impacts to the 

environment and to meet requirements for associated permits required for the Project. 

8.1. Stakeholder Involvement 

The proposed Transloading Facility and a portion of the proposed NGL Pipeline is on property 

owned by LRET. The remainder of the NGL Pipeline will cross an additional 29 land parcels and 

an additional 14 property owners. Individual meetings with property owners along the proposed 

pipeline route were notified about the Project and the need for the NGL Pipeline across their 

respective properties. Access agreements were signed with the impacted property owners in 

order to conduct field studies along the route. The property owners allowed access for the studies 

which were presented in the EA. No property owner along the pipeline route has expressed 

concerns with the Project or the proposed NGL Pipeline. LRET will continue to coordinate with 

property owners for the NGL Pipeline. 

In addition to the individual property owners, FRA conducted Section 106 consultation with four 

federally-recognized Tribes. These Tribes included: 

 Eastern Shawnee Tribe of Oklahoma 

 Miami Tribe of Oklahoma 

 Osage Nation 

 Seneca-Cayuga Nation 

FRA invited these Tribes to participate in the Project as a consulting party in the Section 106 

process. Section 106 consultation packages, including the cultural resource report, were sent in 

hardcopy to each Tribe on March 16, 2020. No responses were received to this initial 

consultation. FRA emailed all four Tribes regarding the Project on April 16, 2020. The Miami 

Tribe of Oklahoma responded via email on April 16, 2020 and indicated that Monroe County was 

outside of their area of concern. 

FRA then sent a follow up letter to the three Tribes that had not yet responded on July 10, 2020. 

This follow up letter detailed the Section 106 process and the open 30-day public comment period 

for the EA. This letter contained the original March 16, 2020 consultation package. The follow 

up letter was sent to all three Tribes in hardcopy and via email. No responses were received by 

FRA from this follow up letter. 

8.2. Public Involvement and Participation 

No public meetings or hearings were held for the Project. Public meeting and newspaper notices 

will be conducted for the Ohio EPA Air Permit, as described in Section 1.5 of the EA, that will be 

submitted for the Transloading Facility. These meetings and notifications will be conducted in 

accordance with the requirements of the Ohio EPA. 

The FRA publicly released an EA for a 30-day public comment period, which began on July 10, 

2020 and ended on August 10, 2020. A notice was placed in the Intelligencer (Wheeling News-
35 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Register) on July 10, 2020 and the Monroe County Herald on July 16, 2020. The notices 

presented a summary of the project and provided access information to Project web site 

(https://www.longridgeenergy.com/businesses/natural-gas-liquids-infrastructure) and the 

government docket web site (https://www.regulations.gov/docket?D=FRA-2020-0049) where a 

copy of the EA was available for review and comment. 

During the comment period, two comments were received. The comments are included in 

Appendix A in their entirety. FRA’s responses to comments received are detailed below: 

 One comment by an individual in support of the Selected Alternative was received on 

August 6, 2020. 

o Comment noted. 

 One comment by the organization FreshWater Accountability Project was received on 

August 10, 2020. This commenter had concerns on aspects of the EA, including the 

purpose and need, market conditions, and EA assumptions, and requested additional time 

for public review. 

o The commenter points to a current depression in the NGL market due to the 

fluctuations in pricing and demand from market shifts of the COVID-19 and 

subsequent fiscal emergencies. The commenter’s concerns about the purpose 

and need for this project focus on the current market conditions; however, once 

the public health emergency related to COVID-19 is controlled and the economy 

recovers, development of the resources in this area is expected to 

continue.1 FRA’s analysis assumes a non-emergency situation in its impacts 

and assumes that the current situation is a deviation rather than a continued 

state. In addition, the commenter refers to a proposed ethane cracker and thane 

storage facility (Mountaineer), but the Appalachian NGL Hub Rail Transloading 

facility and pipeline is not planned for the ethane market and would not be tied to 

the cracker (plastic) industry. The local cracking plant may be on hold, but the 

Shell Cracker in Beaver County, Pennsylvania is still under construction. The 

products planned for the NGL Transloading Facility include propane, butane, and 

natural gasoline. Moreover, propane prices have shown a steady increase since 

April 2020 and the drop in propane prices appears to be more related to annual 

cycles and not the pandemic.2 The propane production from the Midwest has not 

changed appreciably since September 2018. The US Energy Information 

Administration predicts a decline in hydrocarbon gas liquids (HGLs) in 2020, but 

a recovery and increase in 2021.3 FRA’s NEPA process analyzes the 

environmental impacts of the project and does not issue permits or other 

authorizations. The FRA provided 30 days for public review, in accordance with 

23 Code of Federal Regulations 771 and FRA does not believe additional public 

review is needed. 

1 US Department of Energy (DOE) Primer published June 27, 2018, projects that Appalachian NGL products will

increase over 700 percent from 2013 to 2023 (US DOE 2018). 2 https://www.eia.gov/petroleum/weekly/propane.php 3 https://www.eia.gov/outlooks/steo/report/us_oil.php
36 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

8.3. Agency Coordination

In their role in implementing the Selected Alternative, LRET will obtain Federal and State permits, 

as required, prior to development of the Transloading Facility and NGL Pipeline. As the grantee, 

Monroe County will ensure receipt of the applicable permits and compliance with all permit 

conditions. During the EA process, LRET coordinated on the preparation of the required permits, 

particularly for the NGL Pipeline, as described in Section 1.5 and 4.0 of the EA. A summary of 

the agencies that have been contacted during the permitting and EA process are listed below and 

will continue to be engaged through the permitting process. 

 United States Army Corps of Engineers: Individual/Nationwide Permitting, Section 10 

Permit 

 United States Fish and Wildlife Service, Ohio and West Virginia Offices: Endangered 

Species Act compliance. 

 Ohio Department of Natural Resources: Required for Ohio EPA 401 Water Quality 

Certification permit. 

 Ohio Environmental Protection Agency: 401 Water Quality Certification (WQC) for the 

NGL Pipeline and Transloading Facility air permit. 

 West Virginia Department of Environmental Protection: 401 Water Quality Certification 

(WQC) for the crossing of the Ohio River. 

 Ohio Historic Preservation Office: Section 106 consultation. 

 West Virginia Division of Culture and History: Section 106 consultation. 

 
37 | Page

Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

9. CONCLUSION 

FRA finds that the Appalachian NGL Hub Rail Transloading Facility as presented and assessed 

in the EA satisfies the requirements of NEPA (42 U.S.C. §§ 4321 et seq.), and Council on 

Environmental Quality (CEQ) regulations (40 CFR parts 1500-1508), 23 CFR parts 771 and 774, 

and the Selected Alternative will have no foreseeable significant impact on the quality of the 

human or natural environment). The EA provides sufficient evidence and analysis for FRA to 

determine that an environmental impact statement is not required for the Appalachian NGL Hub 

Rail Transloading Facility as presented. 

Jamie P. Rennert Date 

Director, Office of Infrastructure Investment 

Federal Railroad Administration 

FRA’s Office of Railroad Policy and Development prepared this document in August 2020 . For 

further information regarding this FONSI contact: 

Amanda Ciampolillo 

Environmental Protection Specialist 

U.S. Department of Transportation 

Federal Railroad Administration 

Office of Railroad Policy and Development 

Environment and Project Engineering Division

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Phone (617) 494 - 2173 

 

JAMIE P. 

RENNERT

Digitally signed by JAMIE 

P. RENNERT 

Date: 2020.08.28 13:45:08 

-04'00'
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Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

Appendix A: Comments on the EA

Public comments for the EA were collected using Regulations.gov.  The EA was Docket ID: FRA‐2020‐

0049.  During the public comment period for the EA, two comments were received.  FRA’s responses to

these comments are shown in Section 8.2 of the FONSI.   

Comment 1

Tracking Number: kdi‐wo78‐1n5p

Comments Received: August 6, 2020

Submitter Name: Taylor Abbott

Comment Submitted:

Monroe County and the Ohio Valley region stand to gain significant economic and workforce benefits as

a result of this project. Historically, Monroe County has consecutively had the highest unemployment

rate of any county in the state of Ohio. The approval and completion of the Appalachian NGL Hub Rail

Transloading Facility has the potential to be a catalyst for future industrial and commercial development

that is frankly needed in southeast Ohio, particularly here in the Ohio Valley. It is my express hope that

this project comes to fruition.

Comment 2

Tracking Number: 1k4‐9iap‐jo4k

Comments Received: August 10, 2020

Submitter Name: John Heer

Comment Submitted:

On behalf of FreshWater Accountability Project, I am respectfully submitting comments regarding the

Appalachian NGL Hub Rail Transloading Facility Draft Environmental Assessment ("NGL Transloading

EA"). Freshwater Accountability Project is a nonprofit organization with a mission to preserve freshwater

supplies, is dedicated to promoting health by protecting the environment in Ohio, and has members

located throughout the state of Ohio, including members along the Ohio River who will be directly

affected by the proposed Appalachian NGL Hub Rail Transloading Facility ("NGL Transloading Facility").

Fundamental Assumptions Underlying The Environmental Assessment Are Flawed And Should Be

Reevaluated.

The NGL Transloading EA is flawed because it is based upon assumptions which can be proven to be

inaccurate. For example, the NGL Transloading EA begins in the very first sentence with the statement

that the NGL Transloading Facility will be constructed "to support the continued need for transportation

of Natural Gas Liquids (NGL) to end‐use markets." NGL Transloading EA, Section 1.1 Introduction at page

1‐1. However, there is ample evidence that the assumption of a "continued need for transportation of

[NGL] to end‐use markets" is misplaced or just plain wrong.

The petrochemical industry is undergoing a massive shift in both public perception and public need. The

pandemic has taught us that some of our common practices and thinking must change, and that our
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Finding of No Significant Impact

Appalachian NGL Hub Rail Transloading Facility

August 2020

common assumptions must be reevaluated. This includes the incorrect assumption that NGL

transportation will continue to be needed in this area. The Institute for Energy Economics and Financial

Analysis (IEEFA) has stated that the petrochemical industry faces significant challenges. IEEFA's report,

"Proposed PTTGC Petrochemical Complex in Ohio Faces Significant Risks" (March 2020), questions

whether projects like the NGL Transloading Facility will provide the anticipated jobs, tax revenues and

other spinoff benefits to the State and the people of southeastern Ohio, as proponents claim. "The risks

are becoming insurmountable. The price of plastics is sinking and the market is already oversupplied due

to industry overbuilding and increased competition," said Tom Sanzillo, IEEFA's director of finance and

author of the report.

The report identifies principal risks as:

Plastics prices today are 40% below the 2010‐2013 period when the project was originally proposed.

Weak prices will drive profit margins below investment targets.

Oversupply from a global industry‐wide plastics buildout is likely to drive prices and revenues down.

Supply/demand imbalances are likely to last through 2026.

Stiff competition from major companies ‐ ExxonMobil, Dow Chemical, Chevron that have existing

relationships in the U.S. market.

Slower U.S. (and global) economic growth projections by the International Monetary Fund suggest a

slowdown that will impact both volume and prices.

Uncertainty over federal government policies add to the risk factors.

Moreover, the Mountaineer NGL storage project lost its environmental permit in March 2020. Powhatan

Salt Company and the sponsors of the Mountaineer Storage Project allowed a state environmental

permit to expire in March 2020. Why? Because construction of the project's most promising potential

customer, the PTT Global Chemical (PTTGC) Petrochemical Complex, has been delayed due to the

weakened state of cracker plant and plastic markets.

2020 will not be a year when the company's margins improve, as plastics prices have started the year

low and the Chinese market, a major buyer of PTTGC's products, is showing signs of a slow year. Starting

a new expansion now would be a risk to the company's credit rating. The market outlook is much

weaker than when the projects were originally planned. The profit margins for cracker and plastics

plants have declined over the past five years. It remains to be seen if PTTGC's prior expressions of

interest in using the storage facility still hold.

Obtaining the permit was essential for Mountaineer's sponsors and important for reassuring an investor

like Goldman Sachs that they could maintain confidence in the project. Poor market conditions and

more time needed to get the project moving forward means it has become more risky, and that means

more expensive. The situation at Mountaineer demonstrates that the granting of an environmental

permit does not change the fundamental market dynamics of a project. From the very first sentence of

the NGL Transloading EA to the cumulative impact analysis, the assumptions underlying the NGL

Transloading EA are simply flawed and should be reevaluated.

We request that more time and information be provided regarding the NGL Transloading Facility, and

the Federal Railroad Administration should provide a public hearing, extend the public comment period,

and prepare a full Environmental Impact Statement under NEPA.