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Submar Job #12561 – Pipeline Maintenance (Action No. SPA-2014-00070)

Posted: 7/14/2014

Expiration date: 8/18/2014

SUMMARY:  The U.S. Army Corps of Engineers, Albuquerque District (Corps), is evaluating a permit application from Kinder Morgan to conduct pipeline maintenance.  The project will result in permanent impacts to approximately 0.01 acre of waters of the United States in an unnamed tributary to Jaquez Arroyo.  The purpose of this public notice is to inform interested parties of the project and to solicit comments.

AUTHORITY: This application is being evaluated under Section 404 of the Clean Water Act for the discharge of dredged or fill material in waters of the United States (U.S.).

APPLICANT:  Kinder Morgan, ATTN: Lloyd Knuckles, 1001 Louisiana Street, Suite 1000, Houston, Texas 77002

LOCATION:  The project site is located in San Juan County, Section 16, Township 32 North, Range 12 West, Latitude 36.97835 North, Longitude -108.09236 West, San Juan County, New Mexico.

PROJECT DESCRIPTION:  Kinder Morgan Cortez, 30” diameter CO2 pipeline at M.P. 62 crosses through an unnamed drainage course approximately 12 miles south of Aztec, New Mexico (GPS coordinates: 36.97835°N, 108.092363°W). A TransColorado, 24” diameter natural gas pipeline is located on a horizontal 45-foot offset from the CPL in this 40-foot right-of-way (ROW) as well. Both the bed and the banks are composed of sandy clay; the banks are nearly vertical and are grossly unstable. Overflow from a monsoon in September has caused bed degradation and head cutting, exposing approximately 7 linear feet of the Cortez pipeline.

Kinder Morgan proposes to armor the Cortez, 30” diameter CO2 pipeline at M.P. 62 with a series of articulating concrete mattresses for an approximate distance of 31linear feet across the unnamed drainage course and up both banks to cover and protect the pipeline. The sloughing banks will be graded to a 2 horizontal to 1 vertical uniform slope gradient that will day light into the existing topography. The proposed grading plan has a balanced earth work quantity; thus, no import fill material will be required. The manufactured grade will be covered with a woven geotextile material, and on top of it a series of Submar concrete mats will be placed. The upstream and flank edges of the mat system will terminate within 3-foot deep and 2-foot deep anchor trenches, respectively. A subgrade rock grade control will be placed on the downstream end of the series of mats in order to prevent any future scouring within the bed of the drainage course. Submar’s articulating concrete mat series will provide and maintain cover over the pipeline in the matted area.

The Submar Revetment Mattress is an articulating concrete mat used primarily for erosion control.  The mat is 4.5-inches thick and has a low hydraulic profile when placed in a streambed.  Pipeline companies prefer our mats to protect their pipelines for several reasons.  If the area undergoes significant changes, the mats can be repositioned to compensate for changing flow patterns.  The mat has open areas that allow re-vegetation through the mat.  The design for matted areas includes a rapid return to a natural appearance.

PURPOSE AND NEED:   Kinder Morgan is required to conduct maintenance to restore cover to the existing pipeline to ensure continued safety and reliability.  It is expected that without work to repair the present conditions, the banks and bed will continue to erode, exposing more of the pipeline.  At some point, unless maintenance to restore cover is conducted, the pipeline may likely suffer structural damage.

PROPOSED MITIGATION:   Project is designed to minimize the amount of material to be placed within the stream, but maximize the protection of the currently exposed pipeline.  This project will serve to mitigate stream bed degradation due to headcutting and erosion.  The mat system will hold streambed grade and once installed, the mats will collect sediment and their open cell design will support vegetation growth.  Temporary impacts are anticipated during construction; however, no long-term adverse impacts to the project area anticipated.  Therefore, mitigation is not proposed for this project.


State Water Quality Certification.  The applicant is required to obtain water quality certification, under Section 401 of the Clean Water Act, from the New Mexico Environment Department.  Section 401 requires that any applicant for an individual Section 404 permit provide proof of water quality certification to the Corps of Engineers prior to permit issuance.  For any proposed activity on Tribal land that is subject to Section 404 jurisdiction, where the tribe does not have water quality certifying authority, the applicant will be required to obtain water quality certification from the U.S. Environmental Protection Agency.


Environmental Setting.  The Kinder Morgan CO2 gas pipeline is aligned generally on a northwest/southeast axis within the project area.  The work area associated with the project is set on a flat to gentle slope, which is dominated by Great Basin Desert Shrub (big sagebrush) vegetation with small pockets of lower coniferous woodland located approximately 250 feet west of the project area. There are no significant rock outcrops or exposed geological formations within the project area, nor were there any trees or manmade features such as telephone or transmission line poles within the project area.


Alternative 1 – Do Nothing.  The “do nothing” alternative does not meet the need to protect the exposed CO2 pipeline. The pipeline needs to be recovered with earth to function as it was originally designed, since it cannot be exposed to the atmosphere due to increased potential for corrosion or potentially being struck with flowing debris during a flood event. Washout areas along the pipeline, if left untreated, will result in areas of unsupported pipe. These pipelines were designed at elevations so that the surrounding dirt would provide restraining forces to counteract possible loads that could cause pipeline failure. The cost of a “do nothing” approach is immeasurable since the threat of failure of these high pressure pipelines compromises the wellness and safety of personnel and the surrounding environment.  Kinder Morgan is obligated to inspect the pipeline, repair any such deficiencies and correct any safety-related conditions; therefore, the “do nothing” alternative is not a feasible option.

Alternative 2 – Lowering the Pipeline (Open Cut Trenching).  In order to lower the existing pipeline to an adequate depth below the existing stream bed, significant excavation would be required. Construction activities could impact at least 2 acres, and could last at least 5 weeks. This disturbance near the creek could have lasting effects on the existing habitat and ecological system. Environmental impacts would be most unfavorable for this alternative.

In addition to having the most significant impact on the stream bed and banks, this alternative also adds the risk of other environmental impacts because it requires the shutdown of pipeline operations, purging the pipeline, cutting and welding the pipeline back together at a lower elevation while maintaining gradual slopes, and protecting the integrity of the pipeline from complications due to increased backfill loads.   With pipeline separation, cutting, welding, and additional loads due to backfill, the risk of incident and repair complexity increases.  This alternative is also the most expensive of the alternatives listed.

Alternative 3 – Lowering the Pipeline (Horizontal Directional Drilling).  Horizontal directional drilling is a trenchless method of pipe installation where a pipeline is bored underground using a surface-launched drilling rig. This method has minimal impacts on the environment and surrounding area; however, due to the number of washouts per year and the condition of the washouts, this option would not be economically feasible.

There are approximately 10-15 washouts per year along Kinder Morgan pipelines. Most washout areas do not require extensive construction methods, such as directional drilling, for remediation. Similar to the open cut trenching option, horizontal directional drilling would require the shutdown of pipeline operations.  Based on the quantity and condition of the washouts, the option for horizontal directional drilling would be excessive in terms of time required for repair and cost.

Alternative 4 – Articulated Concrete Matting.  The use of articulated matting stabilizes the stream bed/banks and will protect the pipeline.  Kinder Morgan is proposing to install an articulated concrete matting system to cover the exposed pipeline and extend the mat system up both banks of the stream for additional bank stabilization.  To accomplish this, both banks will be graded to create gentle slopes.  The matting will then be anchored in the stream bed on the upstream end of the proposed project.  This matting system will provide and maintain cover over the pipelines and thereby stabilize the stream channel.  Additionally, the spacing in the matting will allow alluvial sediment to settle, thus allowing native vegetation to be established. The articulated concrete matting option would cost less than lowering the pipeline, would have minimal impacts on the environment, and can be completed in a timely manner without disrupting the operation of the pipeline. Using the articulated concrete matting also requires the best construction methods for protecting the safety and welfare of personnel and the environment.

EVALUATION FACTORS:  The decision whether to issue a permit will be based on an evaluation of the probable impacts, including cumulative impacts, of the described activity on the public interest.  That decision will reflect the national concern for both protection and utilization of important resources.  The benefit, which reasonably may be expected to accrue from the described activity, must be balanced against its reasonably foreseeable detriments.  All factors which may be relevant to the described activity will be considered, including the cumulative effects thereof; among those are conservation, economics, aesthetics, general environmental concerns, wetlands, historic properties, fish and wildlife values, flood hazards, floodplain values, land use, navigation, shoreline erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, mineral needs, consideration of property ownership and, in general, the needs and welfare of the people.  The activity's impact on the public interest will include application of the Section 404(b)(1) guidelines promulgated by the Administrator, Environmental Protection Agency (40 CFR Part 230).

The Corps is soliciting comments from the public, federal, state, and local agencies and officials, Indian tribes, and other interested parties in order to consider and evaluate the impacts of this proposed activity.  Any comments received will be considered by the Corps to determine whether to issue, modify, condition, or deny a permit for this proposal.  To make this decision, comments are used to assess impacts on endangered species, historic properties, water quality, general environmental effects, and other public interest factors listed above.  Comments are used in the preparation of an Environmental Assessment and/or an Environmental Impact Statement pursuant to the National Environmental Policy Act.  Comments are also used to determine the need for a public hearing and to determine the overall public interest of the proposed activity.

HISTORIC PROPERTIES:  A cultural resources survey was conducted at the time that the subdivision was originally permitted.  The Corps has determined that the project will have no effect to cultural resources.

ENDANGERED SPECIES: The Corps has reviewed the U.S. Fish and Wildlife Service's latest published version of federally-listed endangered and threatened species located in San Juan County, New Mexico, to determine if any listed species or their critical habitat may occur in the proposed project area.  The Corps has made a preliminary determination that the proposed project will not affect any federally-listed endangered or threatened species or their critical habitat that are protected by the Endangered Species Act.

FLOODPLAIN MANAGEMENT:  The Corps is sending a copy of this public notice to the local floodplain administrator.  In accordance with 44 CFR part 60 (Flood Plain Management Regulations Criteria for Land Management and Use), the floodplain administrators of participating communities are required to review all proposed development to determine if a floodplain development permit is required and maintain records of such review.

CLOSE OF COMMENT PERIOD:  All comments pertaining to this Public Notice must reach this office on or before August 18, 2014, which is the close of the comment period.  Extensions of the comment period may be granted for valid reasons provided a written request is received by the limiting date.  If no comments are received by that date, it will be considered that there are no objections.  Anyone may request, in writing, that a public hearing be held to consider this application.  Requests shall specifically state, with particularity, the reason(s) for holding a public hearing.  If the Corps determines that the information received in response to this notice is inadequate for thorough evaluation, a public hearing may be warranted.  If a public hearing is warranted, interested parties will be notified of the time, date, and location.  Comments and requests for additional information should be submitted to:

Chris Wrbas, Project Manager
US Army Corps of Engineers, Albuquerque District
1970 E. Third Avenue, Suite 109
Durango, CO  81301
(970) 259-1582
FAX: (970) 259-1658

Please note that names and addresses of those who submit comments in response to this public notice may be made publically available through the Freedom of Information Act.