19860073 Ver 1_COMPLETE FILE_19861022

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NKDATA DF/CAMA/401 REV DATE 10/20/86
ACTION > INQ FILE > DFCAMA401 PSWD > ,FORMAT > NRDFCAMA NEXT RCD > 00074
RECORD HAS BEEN CHANGED, RECORD NO 00073 FRD DATA
PROJO: 00073 PROJ: TEXAS GULF PIPELINE COUNTY: BEAUFORT
ASSIGNED TO: WJM Wrl'>>- ,.JOINT NOTICE: N
TYPE CEI~:TIF:t'l:-ATIC)N F<ECOMMENDATION DATES
404 PN: 401 I:::E(~: ISSUE: Y I:::ECEIVED:
CAMA ONLY: Y GC: DENY: INITIAL REPORT:
DF/CAMA: GC: HOLD: FINAL REPORT:
RECEIVING STREAM: SOUTH CREEK CLASS: SA BASIN: TAR
COMMENTS:
APPLICANT PROPOSES TO CONNECT EXISTING. 18 INCH STEEL PIPELINE TO AN EXISTING
PUMP STATION. THE EXISTING PIPELINE LIES ON THE BOTTOM OF SOUTH CREEK:
HOWEVER NO EXCAVATION OR FILL IS REQUIRED.
THE PURPOSE OF THE PROJECT IS TO PROVIDE A TRANSPORT SYSTEM FOR CLA~.SLIMES
TO THE COMPANIES CLAY DISPOSAL PONDS
TG IS IN THE PROCESS OF PUTTING TOGETHER INFORMATION RE. THE INTEGRITY OF THE
EXISTING PIPE
ADDITIONAL COMMENTS PENDING--AUTHORITIZATION TO CONSTRUCT ISSUED 9-25-86
OJ

F~Ec;I()N: 0'(

COPIES: WARO-CENTRAL-MILLS-GOSSETT

RECE\VED
OCT 2 2 1986

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860613
860625
861020

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MBK) ro: John Parker

FRCM: Terry Sholar
1HRlJ: Ed McCoy
THRU: Bill Hogarth
SUBJECT: Texasgulf Application for 18 Inch Pipeline

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DATE: August 7, 1986

The Division of Marine Fisheries recommends denial of the application
to use the temporary 18 inch pipeline for clay transfer due to the
potential risks involved. The recent experience of the pipe failure
and discharge of clay material to South Creek resulted in approximately
26 acres of bottom habitat to be lost, strong public concern, and a
large economic cost to the company. Neither the company nor the
Department can afford another such incident. As a result, the potential
risk of an additional pipe failure must be avoided.

Reviewing the pennit application raises several concerns which indicate
potential risk with the use of the temporary pipeline.

1) The proposed pipe was installed on a temporary basis to transfer
sand tailings for dike construction. It has been in place con-
siderably longer than intended and will be used for something
it was not intended. .

2) The monitoring and failure of the pipe will immediately result
in deposition of clay material in South Creek. As experienced
in the previous episode, rupture and deposition can occur rapidly.
Moni toring by boat weekly, pressure testing monthly, and a pump
pressure alann appear to be inadequate to prevent significant
discharges should failure occur again.

3) There appears to be a question about the subsidence of the
temporary pipe in the South Creek sediments. Subsidence and
rupture is indica too as a possible reason for failure of the
original pipe. Due to the length of time the temporary pipe
will be in place, the potential for subsidence, tension, and
rupture is a very real risk that mayor may not be monitored
on an adequate basis.

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John Parker
Page Two
August 7, 1986

4) Portions of the pipe i.e., near shore and in the channel, are
above the creek bottom. As a result, there is no guarantee
that the pipeline would not be hit or damaged. In addition,
considering the strong public sentiment, the concern over sabatoge
cannot be ruled out.

5) Another factor involves the length of time the pipe will be in
use. The longer the temporary pipe is used increases the risk
of failure due to subsidence, scour, etc. The use of the pipe
is intended lliltil the new 30 inch pipe can be installed. Con-
ceivable, the temporary pipe could be in use for a long time
depending on the permitting of the new line, company funding of
the new line, and possible deliberate delays for reasons such as
cost containment, engineering disagreements, and public involve-
ment. It would appear at this time that th~ effort should be put
into getting the new 30 inch line in place as soon as possible.
Wi th the temporary line in use, the temptation for delay will be
strong for various reasons. Every delay in putting the new pipe
designed for this job in place further increases the risk of
failure of the temporary pipeline.

Overall, the potential risk to the South Creek resources appear to be great
compared to the benefi t derived for the company. Concei vably, the temporary
pipe could be used lliltil the new pipeline is in place. However, there is
inadequate safeguards, monitoring, and failure containment involved with
this pipeline. Each of these involves risk that are llilacceptable if another
failure occurs. As a result, we recommend denial of this permit and highly
recommend that a new pipe with adequate safeguards move forward as soon as
possible.

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DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality Section

September 30, 1986

M E M 0 RAN DUM

SUBJECT:

JOhn~rker

~ MillS~_

Application for CAMA Permit
Texasgulf Chemicals, Inc. - Existing Pipe
Beaufort County

TO:

FROM:

The Subject app~ication has been reviewed for water
quality impacts and the following comments are offered:

1. This project will not require a 401 Water Quality
Certification.

2. The approval to use this pipeline (Authorization
to Construct) has been issued on September 25,
1986.

3. Based upon the information submitted and the
conditions of the Authorization to Construct being
met, we do not object to the CAMA permit.

dtl dkb

cc: Jim Mulligan

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State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street · Raleigh, North Carolina 27611

James G. Martin, Governor
, S, Thomas Rhodes, Secretary

September 25, 1986

R. Paul Wilms
Director

Mr. Douglas G. Mercer, Superintendent
Safety and Eiwirornnental Department
Texasgulf Chemicals Company
Post Office Box 48
Aurora, North Carolina 27806

SUBJECT: Authorization to Construct
Clay Slurry Transfer Facilities
Texasgulf Chemicals Company
Beaufort County

Dear Mr. Mercer:

A letter of request for Authorization to Construct was received Septem-
ber 23, 1986. The information submitted including operating precedures have
been reviewed and authorization is hereby granted for the construction and
operation of an 18-inch diameter clay slurry transfer line across South Creek
subject to the following conditions:

1. Prior to operating the transfer line, a hydrostatic test at
150% of the maximum operating pressure must be conducted.
Mr. Jim Mulligan, Washington Regional Office Supervisor,
shall be notified at least 48 hours prior to conducting this
test so that a staff member can be made available to observe
the test and confirm its completion. This test shall be
repeated once per month with the results submitted to the
Washington Regional Office within the fOllowing month.

2. Prior to operating this transfer line, an alarm system shall
be designed and installed such that an alann is sounded in
an area regularly occupied when ever the pressure in the

Pollu/iO/1 PY(,/,l'n/io/1 Pays

Po. Box 27687, Raleigh. North Carolina 27611-7687 Telephone [phone]

An Equal OpPOrtUnity Affirmative Action Empioyer

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Mr. DOu'~. Mercer
Septemb~r~ 1986 .
Page 2

transfer line rises above the maximum operating pressure
or falls below the minimum operating pressure. Mr. Jim
Mulligan shall be notified when this system is in place
so that _an on-site demonstration can be observed. This
system must be in operation during all times when the line
is in use.

3. Texasgulf Chemicals Company shall notify Mr. Jim Mulligan
of any alarm incident by telephone by the next work day.
A written report shall be submitted to the Washington
Regional Office monthly which reports details of any
alarm incident.

4. This authorization shall expire on January 1, 1987, and
the use of this transfer line shall be terminated on or
before this date.

Upon satisfactory completion of the on-site inspections listed in Item
1 and 2 above, Mr. ~fulligan will provide written authorization to proceed
with the operation of the line. .

This Authorization to Construct is issued in accordance with Part III,
Paragraph C of NPDES Permit No. NC0003255 issued December 16, 1981, and shall
be subject to revocation unless the facilities are constructed and operated
in accordance with the conditions and limitations specified in Permit No.
NC0003255.

In the event the facilities fail to perform satisfactorily, the permittee
shall take such immediate corrective action as may be required by this Division,
including the elimination of the use of this line..

If you have any questions or need additional information, please contact
Mr. Jim Mulligan, Washington Regional Office Supervisor, at [phone].

Sincerely,
O~lGtNAL SIGNED BY
R_ PAUL WILMS
R. Paul Wilms
Director

cc: Jim Mulligan
Arthur Mouberry../

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State of North Carolina
Department of Natural Resources and Community Development
Division of Coastal Management
512 North Salisbury Street · Raleigh, North Carolina 27611

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James G. Martin, Governor
S, Thomas Rhodes, Secretary

David W Owens
Director

June 26, 1986

Mr. John
Water P
Div' on
eigh,

7611

Mr. Sutherland:

The attached copy of an application submitted by:

Texasgulf Chemicals Company
Applicant's Name

SOlfth Creek
Location of Project

Beaufort
County

for a State permit to perform excavation and/or fill
work in coastal North Carolina and for a CAMA major
development permit...

--x-

for a CAMA major development permit (only) ..,

... is being circulated to State and Federal agencies having jurisdiction
over the subject matter which might be affected by the project.

Please indicate on the reverse side of this form your viewpoint on
the proposed work and return it to me not later than 7/1R/Rh

Sincerely,

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Major Permits Processing Section

JRP:ap:2480

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State of North Carolina..... ftal.01S"!\ ~ 0..

Department of Natural Resources and Community Development
Division of Coastal Management
512 North Salisbury Street · Raleigh, North Carolina 276tt

James G. Martin, Governor
S. Thomas Rhodes, Secretary

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AP 2 . 6 .

David W Owens
Director

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18 April 1986

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Field Services
P.O. Box 1507
Washington, NC 27889
[phone]

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Mr. Don F. DeLong
Plant Manager
Texasgulf Chemicals Company
P.O. Box 48
Aurora, North Carolina 27806

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Subject: CAMA Pennit Requirerrents
18 Inch Sand Tailings Pipeline
South Creek
Beaufort County

Dear Mr. DeLong:

Recently I received a letter from Mr. Doug Mercer dated 21 March 1986 requesting
pennission to use the existing sul:merged 18 inch sand tailings pipeline across
South Creek to pump clays into the clay settling ponds.

As you are aware, the existing pipeline was pennitted on 23 FebroaIy 1981 with a
CAMA Minor Developnent Pennit. A recent reviE!'.V of our files concerning the project
indicates that all correspondence from Texasgulf Inc. and to Texasgu1f Inc. addresses
the fact. that the pipeline was to be used temporarily only for the transport of
sand tailings.

Upon reviewing Mr. Mercer's proposal on 21 March 1986, the Division of Coastal
Management decided that the use of the existing 18 inch pipeline for the transport
of clay materials will require a CAMA Major Deve10pnent Pennit. Mr. Mercer was
infonned of this decision verbally shortly after the receipt of his letter. Also
as you are aware this matter was discussed during our rreeting at the Washington
Office on 7 April 1986.

On 14 April 1986 I received a copy of a letter to Mr. Doug Mercer from Mr. R. Paul
Wilms, Director, N.C. Division of Environmental Management, the subject of which was
a discussion of his agency's position on the use of the 18 inch pipeline for clay

P.D. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]

An Equal Opportunity Affirmative Action Employer

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transport. In this letter, Mr. Wilms requested documentation f:rom the Division of
Coastal Management on the present status of the pipeline in regards to this Division I s
penni t requirements. I am by copy of this letter notifying Mr. Wilms that a CAMA
Major Development Pennit will be required by the Division of Coastal Management for
the 18 inch pipeline to be used to transport clay materials.

If you have any questions concerning this matter, do not hesitate to contact me.

...
Sincerely,
&6.tMCl '4... ~
David L. Gossett
Environmental Consul tal1t

DLG/aht

cc: Charles Jones - Chief, Field Services Section, DCM
Kjill Jolly - U.S. Anny Corps of Engineers
~. Paul Wilms - Director, NC Division of Environmental Management
Jim Mulligan - Regional Supervisor, DEM, Washington Office
lX:>ug Mercer - Texasgulf Chemicals Company