2011-05-12_PERMIT FILE - M2011028 (2)

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associated with carcinogenesis (Lee and Grant 1981). Elevated levels of PAHs have been reported in the Animas River, but the source is unknown (Wilson et al. 1995). Levels of PAH compounds have also been found in the bile of most fishes from the San Juan River, indicating high current concentrations in that system. 4.2 Conservation Measures Reclamation has committed to a number of mitigation measures in the FSEIS to reduce or eliminate impacts from the construction of the ALP Project, including pipeline construction. Reclamation makes additional commitments in the EA (see section 5.2). The two actions below relate to ESA compliance activities and the FWS Coordination Act Report (see FSEIS, Volume 3, Appendix 7)(Reclamation 2000a) and are included in section 5.2. 1) Either alternative will require a high standard of leak detection monitoring. The Bureau of Reclamation will be expected to adopt state-of-the-art practices to ensure that the risk of exposure to aquatic resources is minimized, and that plans and staff are available to respond to and remediate threats immediately. An alignment selected that is predicted to have a greater risk to terrestrial and aquatic resources will be expected to have a more sophisticated monitoring and remediation regimen. The potential for release of petroleum product into Ridges Basin Reservoir exists with a leak or break in the MAPCO pipeline. Reclamation would implement or have implemented the following measures that would apply to the 10-inch-diameter MAPCO petroleum products pipeline. Other than the first commitment which would apply to all pipeline construction, these would be implemented when MAPCO receives appropriate permits and clearances to convert the 10-inch-diameter pipeline from NGLs to petroleum product. The time at which this conversion would occur is presently unknown. Best practices would be used by crews to minimize spills of hazardous materials during construction that could get into waterways. Spill avoidance technology would be implemented to minimize the risk of a spill in the petroleum product line. MAPCO would use pipe for their 10-inch-diameter pipeline in the Ridges Basin area with wall thickness equivalent to that of the pipeline crossing the Animas River (0.250 inches), and with greater steel strength (stepped up from 60X to 65X). This measure is taken to minimize the risk of a leak or spill from the pipeline. Initial operation of this pipeline would transport NGLs. When conversion to petroleum product occurs, the thicker, stronger pipe would be in place as a safety assurance against spills at or near sensitive water ways. Appropriate technology would be implemented to minimize the volume of a spill from the petroleum product line. This technology may include motorized block valves, check values, pump stations, detection cable with satellite link, or other current technology. This technology would be implemented before petroleum product is transported through the pipeline to minimize the volume of spill as analyzed in the Environmental Assessment and Biological Assessment of this project. This technology would include an in-line inspection system, such as a SCADA monitoring system, to allow early identification of leaks as small as 1.0 bph. An Emergency Response Plan for operations would be developed that details measures to contain spills and prevent further dispersal. This plan would require a response team on- site within 1 hour of leak detection. This plan would include the establishment and maintenance of on-site equipment and materials needed for hazardous spills clean-up. B-15 Weern-inuche Construction Authority P.O. Box AA - I owaoc, CO 81334 ptisiMA5 CgLA--iea e-VA.Y6L 6V_tA%(!:,tT- H P4cvs H-&-f