Review and analysis of the proposed trans mountain oil pipeline to be constructed within Skagit Co for Skagit County

[From the U.S. Government Printing Office, www.gpo.gov]

REVIEW AND ANALYSIS OF.THE
PROPOSED TRANS MOUNTAIN OIL PIPELINE
TO BE CONSTRUCTED WITHIN SKAGIT CO.

FOR

SKAGIT COUNTY

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LEONARD AND. BOUDINOT, INC.
CONSULTING ENGINEERS
BURLINGTONI WASHINGTON

APRIL 30, 1981'

"The preparation of this report was aided
through a grant from the Washington State
Department of Ecology with funds obtained
from the National Oceanic and Atmospheric
Administration, and appropriated for Sec-
tion 308(b) of the Coastal Zone Management
Act of 1972".

JOHN E. LEONARD, JR., P.E. & L.S.
Jtxonard and Boudinot
MOORPORATM ROBERT C. BOUDINOT, JR., P.E.
PROFESSMAL ENGINEERSand LAND StJRVEYOFtS

April 30, 1981

Mr. Robert C. Schofield
Planning Director
Skagit County Planning Department
County Administration Building
Mount Vernon, WA 98273

Reference.: Review and analysis of.that portion of the Trans Mountain
Oil Pipeline to be constructed within Skagit County

Dear Mr. Schofield:

As per our agreement dated March 3, 1981, we submit herewith our report
on that portion of the Trans Mountain Oil,Pipeline proposed to be con-
structed in Skagit County.

Our analysis of the documents submitted.by Trans Mountain Oil Pipeline,
Corporation has been primarily from an engineer's perspective. We have
raised questions which have not been sufficiently answered in the Trans
Mountain documents and have attempted to identify those particular impacts
relating to specific conditions in Skagit County.

In the course of our review we met with private individuals, public agencies,
and utility companies to elicit their impressions of the proposed oil pipe-
line construction. Letters from various agencies and companies are included
in the appendix of this report.

We look forward to participating with Skagit County in future meetings and
hearings concerning this project.

Yours very truly,

LEONARD D BOUDIN9, INC.

/9Fn/r._ Le Jr., P 4. &

ert"C. Boudinot, Jr., P.E.
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IN Jr., P.E.
Post Office Box 327 612 East Fairhaven Burlington, Washington 98233
Telephone 755-0431

INTRODUCTION

The following report is based on our.review of all documents, maps,
and exhibits submitted by the.Trans Mountain Oil'Pipeline Corporation.
Our study has included interviews with Dike and Drainage District Com-
missioriers, City and County officials, official-s of the U.S.D.A. Soil
Conservation Service, officials of the State Department of Ecology,,
and owners,of private property through which the pipeline will pass.
We have met with Mr. Trevor Durrant, Managerof Administration and
Planning, of the Trans Mountain Oil Pipeline Corporation. We have also
conducted a field reconnaissance of the entire proposed pipeline route
in Skagit County.

In presenting our observati ons, questions, and concerns, we realize
that the information submitted by Trans Mountain does not contaig a
detailed final pipeline.design. Additional engineering studies and a
final design must be submitted and will be reviewed by Skagit County
officials. Many of our questions and concerns should be answered in
the final plans.

MAJOR CONCERNS

Of the many impacts on Skagit County,-we feel there are six major
concerns of which the county should be aware:

Oil Spill
The first and most pervasive concern is the threat of an oil spill
from' rupture of the pipeline or leakage at the Burlington tank farm.
The environmental impacts associated'with an oil spill have been addressed
in considerable detail in the six volumes of the Trans Mountain Oil Pipe-
line Corporation report. We are concerned that adequate analysis of the
physical conditions of the environment through which the pipeline passes
has not been made. We feel that more precise engineering information
concerning soil conditions, ground*water table conditions, fault lines,
river and stream conditions, and pipeline right@-of-way conflicts is neces-
sary to adequately evaluate the structural integrity of the pipeline and
tank farm components.. We have some concerns about the remote computer
operation of the Burlington tank farm (Volume II, Part 1, Page 2-121)
and the lack of full-time.personnel at the Burlington tank farm. We
are concerned with the potential liquefaction of the fine grained soils
in the Skagit lowlands due to earthquakes and the resultant loss of
support for the pipeline. We .need muc.h more information on the direc@
tional drilling technique proposed for the Skagit River crossing and
an examination of alternative construction te-chniques for the Skagit
River crossing.

We realize that the Corps of Engineers, Department of Ecology,
Department of Fisheries, and Environmental-.: Protection Agency will all
be reviewing this pipeline proposal and wi*ll be evaluating the oil spill
risks. For this reason a detailed study of oil spill impacts in Skagit
County is not a part of.this report.

River Crossings
A list of major river and stream crossings is given in Volume II,

Part 1, Page 2-47. Nine crossings are listed for Skagit County:

Milepost Stream Name
95 Carpenter Creek (Fisher Slough)
100 Britt Sl-ough
101.4 Skagit River
104.1 School House Slough
105.4 Heggens Slough
Indian Slough
111.3 Samfsh.River
118.1 Friday Creek
118.7 Friday Creek@,'.,

In the appendix of this report photographs P-1, P-2 and P-3 show
the pipeline crossing location on Carpenter Creek (Fisher Slough) and
photographs P-9 and P-10 show the Skagit River crossing,location.

Our greatest concern is with the Skagit River pipeline crossing.
The Trans Mountain report indicates that this crossing will be made using
a directional drilling technique. This is briefly described in Volume II,
Part 2, Page 4-12. No alternative construction methods for this crossing
are discussed in the report and no alternative river crossing sites are
investigated. A copy of the plan and profile of the Skagit River crossing
is included on Page A-3 in the appendix of this report. This drawing is
a revision of the drawing shown in Volume III, Part 1, Page A-81 of the
Trans Mountain report.

The geophysical* survey of the Skagit River crossing was made in
December 1979 by Harding-Lawson Associates. Results of their investiga-
tion are in Volume III, Part 1, Section A, Page A-196. Their report
indicates that the river was flooding at the time of the investigation
and that they had difficulty obtaining.sufficient information on soil
conditions below the river bed. Mr. Trevor Durrant indicated that
additional soils information from soil borings has subsequently been
obtained but is not included in the report. From the results of the
preliminary geophysical investigations-the report concludes that soils
are sufficiently dense to allow for construction of the river crossing
using the directional drilling technique.

We have the following concerns:

1. As shown on Page A-3 of the appendix of this report, it is
proposed to directionally drill 1,450 lineal feet or approxi-
mately the distance between t he river dikes. Letters from
Dike District Nos.,l and 3 are.included on Pages A-8 and A-9
of the appendix; and photograph P-7 shows the dike south of
the river. The Dike District Commissioners.are concerned that
the pipeline will not be deep enou'gh under the dikes and that
the boring will take,place too close to the toe of the dikes.
Photograph P-8 shows the area adjacent to the south dike where
it is assumed that the drilling will take place.

2. The Trans Mountain report makes no mention of seepag e barriers
or@ trench cut off wa'lls in the pipeline under the dikes., Both
Dike Districts -request some kind of baffle plates around the
pipe or seepage barriers.

3. Insufficient information concerning the directional drilling
technique has been presented in the Trans Mountain report. It
is, therefore, difficult to-address possible concerns. The
depth of the pipeline below the river bottom appears to be
sufficient but we question the ability to control the diameter
of the hole being drilled and are concerned with voids being
created along the pipeline route.

4. We are concerned that the soils conditions under the river may
preclude thedirectional drilling method. We have inspected
well logs for wells adjacent to the river in the vicinity of
the pipeline crossing, and have spoken with local well drillers
and with Dike and' Drainage District Commissioners. There is
the possibility of encountering areas of saturated silty fine
sands or quicksand. A complete soils investigation should be
presented to Skagit County for revi ew

5. Due.to the concerns of the Dike Districts and the information
from well logs, we.think tho.possibility.exists that directional
drilling may have to be abandoned and either open cut the river
crossing or mining may have to be resorted [email protected] impacts and

mitigative measures of,the alternate methods of crossing should
be studied..

The oil pipeline is proposed to be constructed four feet below the
maximum scour depth on all other rivers and streams (Ref. Volume II,
Part 1, Section 7, Page 7-10). No information is given on how the maxi-
MUM scour depth will be determined or on design flood flows on each
river and stream. Mitigative measures for stream crossings are dis-
cussed in Volume II, Part 1, Section 7.1.3.3. We wish to note that
some of these same mitigative measures should be applied to drainage
district ditches crossed by the pipeline. The report points out.that
some rivers such as the Samish will be resistant to constructi on impacts
because of their normally-high turbidity levels. It is hoped that this
will not allow less stringent controls on constr'uction across the Samish
River. Plan, profile, and details of the,Samish River crossing are shown
on Page A-4 in the appendix of this report.

Burlington Tank Farm
The Burlington tank farm and pumping station is to be constructed on
36 acres of land south of the Skagit Regional Airport. Access to the site
will be by Ovenell Road and possibly by a new access road to the airport
proposed to be constructed east of the tank farm site. A complete report
on the tank farm and pump station i.s included in Volume III, Part 3, Sec-
@tion N.

Our concerns with the Burlington tank farm can.be grouped in two
categories: Impacts of construction and impacts during operation.

Construction-Impacts: The Trans Mountain report (Volume III, Part
3, Section 0, Pages 0-9 and 0-10) indicate that the Burlington tank
farm will act as a staging area for the pipeline construction from
West Pass (milepost 89) north to the'tank farm. Pipe will be
barged to Anacortes, and then trucked to the Burlington tank farm
for storage. A total of 46 miles of pipe will be stored at the
Burlington site and then trucked from the site to the pi.pe' laying

crews.

Little information is given in the report on the impacts or pro-
cedures for storing pipe, materials, and equipment at the Burling-
ton tank farm site. We are concerned with the impact of truck
traffic on Highway.20, Highway 537 (Farm-to-Market.Road), and t.he
Ovenell Road. The intersection of Highway 537 and Ovenell Road
is just over the crest of a hill',on . Highway 53.7 which bl,ocks sight
of the intersection.. This.creates a particular hazard with turning
trucks. Ovenell Road is surfaced with gravel and crushed rock and
is not constructed to handle heavy truck traffic. Photograph P-12
in the appendix of this report shows Ovenell Road. Further analysis
of access problems to the tank farm site is needed. Adverse impacts
on transportation facilities is discussed in Volume II, Part 1, Sec-
tion 7, Page 7-28, but no mention ismade under mitigative measures
of any road improvements necessitated by the pipeline construction.
We do not agree with the traffic analysis conclusions that there
does not appear to be any significant project related impacts at
this site. (Ref. Volume III, Part 2, Section K and Volume II,
Part 2, Page 4-174)

The report indicates that.approximately 400 construction workers
will be working out of the Burlington tank farm site (Ref. Volume
III, Part 3, Section 0, Page 0-10)-. It also states' that a total
of 239 construction workers from outside the area are expected to
be in Skagit County in the twenty-second and twenty-third months
of the construction (Ref. Volume II, Part 2, Page 4-134). There
is insufficient analysis of the.impact of these construction workers
on the tank farm site.

-Impacts of the Completed Tank Farm and Pumping Station: When com-
pleted and in operation, the Burlington tank f arm and pumping
station will be operated by computers located in Vancouver, B.C.
and at Low Point. Control of all pumps and valves will be remote
and sensors will transmit data back to the computers through a
communications system (Ref. Volume II, Part 1, Page 2-122). Three
operations personnel and three maintenance personnel would be sta-
tioned at the Burlington tank farm.

We have the following concerns:,

1. It is a concern that an operation ascomplex, expensive, and
potentially devastating to the environment has no onsite per-
sonnel at the Burlington tank farm durin'g periods when the
tanks are being filled or emptied.@ Will the pipeline operators
in Vancouver and Low Point be able to contact emergency services
personnel if their computer system indicates an emergency at the
Burlington tank farm or pumping station? How will security be
handled at the tank farm site?

2. The report indicates that the entire tank farm and pump station
site will be diked and will be covered with an impervious blanket
to prevent seepage into the soils. Storm water runoff will be
controlled on the entire site and will be discharged at the south-
east corner of the site into Drainage District No. 19 ditches.
Insufficient information has been given in.the report concerning
runoff quantity and quality. It is understood that oil@water
separators will be.used, but how will these be operated and
what controls will there be on the quality of discharged storm
water? Retention of peak runoff will be required by the county,
as will control of runoff during construction.

3. A buffer of-trees surrounding the tank farm and pumping station
is mentioned in the report (Ref.-Volume II, Part 2, Pages 4-125
and 4-233). This.buffer wilVielp.to contain the glare of the
site lighting. No buffer of trees is shown on the tank farm
plan in.Volume III, Part-3, Section N, Page N-7. Photograph
P-11 in the appendix of this report shows the east boundary of
the proposed tank farm site. Is the proposed vegetative buffer
to be on the 36 acres of Trans Mountain property? Will light
and glare from the tank farm site have any effect on the opera-
tion of the Skagit Regional Airport? Volume II, Part 2, Section
3, Page 3-324 describes.th6 Skagit Regional Airport at Bayview.
A discussion of the visual impact of the Burlington tank farm is
given in Volume II, Part 1, Page 4-228.

Depth of Burial of Oil Pipeline.
Typical pipeline trench and backfill.requirements are shown in
the Trans Mountain report in Fi gure 2-40 in Volume II, Part 1, Section
2, Page 2-109. This diagram indicates that trench depths will vary
from a maximum of 48 inches to a minimum of 30 inches. Because of the
large diameter of the proposed pipe, the.pipeline route will create a
barrierfor drainage and other utilities from.the south border to the
north border of the county. In interviews with local utility companies,
city and county officials, farmers, and private property owners, con-
siderable conflict with existing oil pipelines due to their shallow
.depth of burial has been indicated. A minimum of 48 inches of cover
over the proposed pipO'ine should be required. In addition, the final
pipeline design should be evaluated for potential conflicts with future
utility extensions in Skagit County..

More information-is needed to properly evaluate the maximum scour
depth at rivers and streams. At most major drainag e ditches a burial
depth of 4 feet below the bottom of the ditch should be adequate to
prevent future obstruction of ditch'cleaning. The proposed 30-inch
burial depth for the pipeline across agricultural lands is too shallow
to allow for the construction of adequate drains and for modern day
agricultural practices..

Easements
The first five'miles of the proposed p ipeline route through Skagit
County will require new right-of-way easements (Ref. Volume I, Page 2-77).
We are,concerned that in the process of negotiation for these easements
the pipeline route may be changed and other impacts will need to be inves-
tigated.

A recommendation has been made by Dike.District No. 3 that the pipe-
line be routed next'to the Burlington Northern Railroad in the south part
of Skagit County. Questions have been asked why the Trans Mountain oil
pipeline is not following the 01-ympi.d Pipeli,ne right-of-way.

In the Burlington to Laurel segment of the pipeline an additional
construction easement 30 feet wide will be necessary. The existing

right-of-way through most portions of this.segment is 50 feet wide.
South of the Stackpole Road a 50-foot wide permanent easement and a
20-foot wide temporary construction easement will be required (Reif.
Volume II, Part 1, Page 2-101). In segments where there is the existing
20-inch oil pipeline the new 36-inch pipe is proposed to be located 10
feet away from the existing pipe and approximately @O feet from the edge
of the 50-foot easement (Ref. Volume II, Part 1, Page 2-103).

We have obtained a few copies of the existing Trans Mountain ease-
ments and noted that not all easement.,agreem ents-allow for the,construc-
tion of a second pipeline.

Construction Inspection and Plan Review
During our interviews City and County Pu blic Works Departments,
Drainage Districts, Dike.Districts, utility companies ., and private prop-
erty owners have all expressed a concern for protection of their inter-
ests during the construction. We recommend that a qualified consultant
be appointed by the county to represent the concerns of the county and
of all special districts crossed by the pipeline. This individual or
firm should have authority to stop the. construction, and should be in
direct contact with the top officials of the Trans Mountain Oil Pipe-
line Corporation. The cost of this construction inspection, should be
borne by the Trans Mountain Oil Pipeline Co rporation.

Many of the people interviewed in Skagit County'related stories
of other pipelines which have crossed the county and the relationships
they have had with the contractors,doing the construction. Due to the
pressure of keeping the job moving, many contractors are.insensitive to
local property owners' concerns. Local property, owners and city, county,
and district officials have been frustrated in the past at not having.a
person to contact to express their individual concerns about the construc-
tion.

CONCERNS

Ground Water
We anticipate that construction of the pipeline through the low
areas of Skagit County will be in areas where the ground water table is'
encountered. On the pipeline route map in the appendix, areas with a
probable shallow ground'water table have bee In shaded. Impacts on ground
water table condi tions could be substantial and need to be discussed in
greater detail.

Concerns: Soils in the upland areas of Skagit Co-unty are generally
impervious clays or glacial till. Ground water will tend to follow the
pipeline trench and may cause drainage problems in agricultural lands in
the transition zone between flat and uphill pipe segments. Seepage along
the pipeline trench should be controlled and trench cut off walls surround-
ing the pipe should be used.

Where the ground water' table is high some form of trench dewatering
may have to be used. This lowering of the ground water table may cause
settling of adjacent lands, may impact adjacent crop land, may lead to
increased turbidity in local drainage ways, may affect wells in the vicin-
ity, and may cause contamination of surface waters due to the intrusion
of septic tank wastes into the dewatering areas., (Ref. Vol.ume II, Part 1,
Pages 1 through 8; Volume II, Part 1 Section 7, Page 7-15)

In the Trans Mountain report, Volume II, Part 1, Pages 3-23i, 3-23j
and 3-23k, areas of shallow ground water in Skagit County are shown. No
indication is made of shallow ground water in the southern segments of
the pipeline. In Volume II, Part 1, Pages 3-125, 3-135 and 3-136, there
is a list of 24 well.s in-Skagit County a long the proposed pipeline route
and maps showing the location of these wells@ A discussion of ground
water in the Skagit River basin is presented on Pages 3-144, 3-145 and
3-146.

An oil spill could ha ve a tremendous impact on the ground water table

and on the permeable soils through which the ground water passes. Oil
spills might occur not only fromthe pipeline, but also from the con-
struction equipment. Potential ground watercontamination in Skagit
County is discussed in.Volume II, Part 1, Page 4-77 and on Pages 4-301
and 4-304. Mention is made of. lining the pipe trench with bentonite
clay or polyethylene-sheets to prevent the downward.and lateral migration
of spilled or leaked oil. '(Ref.; Volume.11, Part 1, Section 7, Page 7-15)

Residential and Public Areas
In traversing Skagit County. the pipeline passes through some resi-
dential areas and very close to the All en Elementary School. (See pic-
ture P-14 in the appendix of this report.) There is little or no dis-_
cussion in the report of the impacts of the construction on'these areas
or of any potential hazards. The majority of the residential neighbor-
hoods are from milepost 102 to milepost 104, as shown on map plates 1
and 2 in the appendix of this report..

Concerns': The impact of constructing the oil pipeline through
residential areas needs to be carefully examined. In addition to the
noise, dust, and hazards of heavy equipment, there may be more far
reaching consequences of const ruction close to buildings. The impact
of the trench excavation on existing septic system absorption fields
should be addressed. The potential damage to structures due to.vibra-
tions from heavy equipment or settlement due to trench-dewater'ing is not
mentioned. There is insufficient information concerning restoration of
ground surfaces after the pipeline is constructed.

Construction schedules given in the report'indicate that pipeline
construction past the Allen Elementary School may occur during months
when school is in session. Disruption of the school should be considered
as well as potential hazards to the school children.

No mention is made of,measures during construction to limit access
to private property during periods when the pipe laying crew is passing
through.

Odors
The Burlington tank farm will be a source of odors. The primary.
source of odors from the tank farm will be volatile sulfur bearing con-
stituents of crude oil mainly composed of hydrogen sulfide and mercaptans.
The report states that,impacts of odors are not expected to extend beyond
about-1 or 2 kilometers from the source, but.that odors should not be
detectable beyond a few hundred meters from the source.

Report Reference: Volume II, Part 1,-Section 4, Pages 66 and 67.

Concerns: Portions of the Skagit Golf,and Country Club residential
subdivision are located within 1.8 kilometers.of the proposed tank farm,
as is the terminal area of the Skagit Regional Airport.

Electric Power
Power from Puget Sound Power and Light Company will be required to
operate the Burlington and Laurel pumping stations., the cathodic protec-
tion systems for the pipeline, the communications.systems, and the tank
farm support facilities.. The report indicates th at Puget Sound Power
and Light Company has approved these power system additions and has stated
that providing power is not a problem.

Report Reference: Volume II, Part'l, Section 4.2.6.1.1, Page 4-193
and Page 4-198 (table of electrical energy requirements).

Concerns: Once in operation the trans Mountain oil pipeline will be
a priority user of electric power. In the event of power shortages due
to low water levels in the reservoirs, will Trans Mountain power require-
ments cause or futher aggravate power shortages to existing commercial
and residential customers? Is it possible that this could increase power
rates?

On Page 4-194 it states that a 1-,I-m'ile extension of 115 KV transmission
line will be required to serve the Bur lington pumpin g station. This trans-
mission line extension is proposed to be built along existing pipeline
right-of-way. In checking pipeli ne easements in Skagit County, we have
not found that they allow construction of power transmission lines. If
this is the case, new easements would.have to be negotiated. Much of the

pipeline right-of-way crosses ag ricultural land, which may be impacted by
location of a power'transmission line.

Waste Disposal for Tank Farm
The Burlington pumping stat.ion and tank farm will have a permanent
work force of.approximately six. Sanitary waste will be disposed.of with
a septic tank system. During construction several hundred construction
workers will work out of the Burlington tank farm site. Holding tanks
and portable toilets will be-used durin.g the construction.

Report Reference:. Volume II, Part 1, Section 4, Page 4-207; Volume
II, Part 1, 'Section 3, Page 3-.357.

concerns: Septic tank Andabsorption field systems may be difficult
to install at the Burlington ta.nk farm site due to impermeable soils and
high ground water table conditions. It should be noted that the city of
Burlington sanitary sewers exist approximately,3,000 feet to the east
along the Ovenell Road from the proposed tank farm.-

Drainage District and Dike District*Concerns
The proposed pipeline route through Skagit County crosses fourteen
major drainage ditches in four drainage districts and four major dikes
in two dike districts. Commissioners' of-the drainage and dike districts
were interviewed'and letters from.Dike District Nos..l and 3 are'included
in the appendix of this report. Photographs P-1 an d P-7 show Dike District
No. 3 dikes, and photographs P-2, P-3, P-4, P-5 and P-6 show Drainage Dis-
trict No.' 17 ditches. Photograph P-13 shows a Drainage District.No. 14
ditch. All photographs 'are included in the appendix of this report.

The drainage district commissioners indicated that a minimum burial
of 4 feet below the bottom of their ditches would be sufficient for the
pipeline in most cases. It was pointed out that maintenance of Fisher
Slough (pipe milepost 95.1) is done with a drag line and a greater depth
for this pipeline crossing may be necessary.

.:Drainage district commissionert-were concerned that construction of
the pipeline would not impede or.block the flow in the ditches and that

.when completed, the ditches would be put',back in-the same condition.
Several of the drainage districts operate and [email protected] buried drains
across agricultural property.. The, proposed minimum.depth of burial
of 30 inches for the pipeline will obstruct these drains'and will
cause considerable'obstruction to future field drain construction. The
pipeline should be buried a minimum of 48 inches across all agricultural
lands. Any field drains 'or tile .lines crossed'by the pipeline shall be
repaired adequately and shall be protected against settlement of the
pipe trench soils.

If it is necessary to lower the ground water table by some form of
trench dewatering, ground water discharged.into the drainage district
ditches shall not contain sand or silt; sha-11 not contain effluents
from septic systems; and shall not c.ause erosion along the drainage
ditches (Ref. Volume II,. Part 1,.Section 7 and Volume 11, Part.1, Pages
4-10 and 4-81).,

Dike and drainage districts,will require that construction through
their facilities shall.be done in the period from June 15 through October
15. This is the dry period when the ground water table is the lowest and
when flooding is least likely. Several-commissioners interviewed pointed
out that soils along the proposed route.tend to behave as quicksand when
excavating below the ground water tabl e. Particularly in the Fisher
Slough area this could pose some difficult construction problems.

Utilities and Roads
In our interviews for this report we met with the.,Skagit Utility
Coordinating Council an d city, county, and utility company officials.
The principal concern expressed by all.persons interviewed was the
proposed-depth of burial of the pipeline. Thirty inches cover over the
pipe is not enough clearance-for construction of other utilities. Most
utilities are.required'by their franchise to have a minimum burial of
30 inches. This puts them in direct.conflict with the proposed pipeline
for any future utility extensions.

Other concerns were for electrolysis of metallic pi.pelines and for
Ioss of stability caused by trench de'watering or excavation close to

existing underground utility lines.

City and county officials should be contacted by Trans Mountain
prior to final design of the pipeline to determine requirements for road
crossings.

Agri cultural Land
Our review of the pipeline route through the Skagit Valley Delta
farmlands reveals that approximately 14b acres of pri.me farmland will be
disturbed during the construction period. We have discussed the possible
effects of this route with Peggy Olds of the Soil Conservation Service,
with farmers at our meetings with various*dike and drainage districts,
and also with other farmers who owned property when the Trans Mountain
pipeline was put in from Canada to the refineries at March Point.

We think that past experience has shown that there is crop loss
extending as long as five years. Existing easements which Trans Mountain
has at this time require the compensation for only the.immediato crop
disturbed during the construction period * The only thing that can be
done for farmers with existing easements across their property is to
bring whatever pressure is available by the county to encourage Trans
Mountain to mitigate the possible long term impacts.. Past experience
has noted substantial disregard for the season of con.struction or the
destruction done during that period. Once the pipeline contracts have
been let, it will be hard for Trans Mountain to.control the timing of
the construction, but possibly.contracts could be structured to permit
construction only from June through September. One drawback for the
pipeline company would be of course the greater crop loss during the
summertime than during the wintertime;, howev 'er,' the destruction to the
fragile topsoil would be considerably less if done during the summer.

Another major existing problem and future problem is the disruption
of field drains which will be frequently encountered within the entire
sixteen miles of lowlands traversed.- The Soil Conservation Service has
much of the information on the lo-catfon of existing tile field drains.
Many of these systems were.installed with federal cost sharing funds,
which committed the owners to mai ntain the drains. for a minimum of ten

years or pay back the federal'money used for,their project.

One, of the major problems is the-depth of the existing pipeline
with a 30-inch cover, which is nearly.exactly' where most field drains
are installed. The new proposed pipe should be-installed at a depth
which will allow field drains above it. Certainly a 40-inch pipe
prohibits any field drains being installed below the bottom elevation
of that pipe. A typical planand profile of field-drai.ns and how the
pipeline would affect them are shown on Page A-5 in the appendix of
this report.

There should also be given consideration to the method of notifica-
tion of the property owners when the construction actually begins. One
of the previous problems in this regard was the lack of notification to
lease holders of property who first discovered the fact that their crop
was going to be removed when the construction crew appeared on the site.
That-cannot be simply answered with the statement that Trans Mountain@.:
will pay for crops removed. There is much-more impact on the farTner
than just the loss of a 75-foot strip of corn or peas. Since the construc-
tion may occur at aboutthe same time they-have field work to perform,
a 75-foot swath interfering with-their operation can.be costly in ways
which are not easily determined and probably not compensable.

In summary, consideration should be given to disruption of field
drain tiles, a change in the drainage characteristics of the soil due
to heavy construction machinery, loss of fertility, unexpected disrup-
tion of lease hold farmers, and the possible'large accumulative cost to
the farm community in legal negotiations regarding losses that will

occur.

Restoration and Cleanup
After construction of the pipe.line, restoration and cleanup of the
pipeline right-of-way will be necessary.

Report'Reference: Volume.II, Part 1, Pages 2-90, 2-107 and 2-11.7;
Volume II, Part 2, Page 7-3.

Concerns:. Very little mention is made of the restoration procedures

'16

cleanup activities, that will be,implemented after-the-construction.
In some places it will'be necessary to construct temporary rIoads across
private properties along the pipe right-of-way.' Removal of these roads
and restoration of the.ground surface needt.to be addressed'. Several
property owners interviewed for this report have expressed concerns about
the right-of-way cleanup.

In discussion.of:.,@agricoltural.-.Iands..in the trans Mountain report it
is mentioned that double ditching will be used to avoid mixing topsoil
with sub soils. It is not mentioned, however, if topsoil will be removed
and stockpiled from areas where roads will be built. Topsoils can.be
damaged and lose their fertility due to rutting and compaction caused by
heavy.equipment.

Mention is made.in Volume II,-Part 2,- Page 7-3 of drainage and erosion
control in the pipeline.right-of-way after construction. It is.stated
that temporary mulching and planting will, be used during construction
and permanent revegetation will be established after construction is
complete. No information is given on the types of revegetation, how
soon after construction revegetation will take place, or how long revege"
tation will be maintained to assure.that it is.growing.

QUESTIONS

l.-How much.Alaska North Slope oil is anticipated to be exchanged for
Canadian crude oil along the Canadian pipeline r6ute?

2. Can Canadian crude'be shipped back to North Puget Sound refineries
after new pipeline js completed?

3. The Burlington tank farm will provide storage for crude oilfor all.
four refineries in the North Puget-Sound area. Does Trans Mountain
'have commitments from any of these refineries for supplying them,with
crude oil? If commitments arenot obtained,.will the Burlington tank
jarm be built? Aie.commitments.from the North Puget Sound refineries
critical to the feasi bility of the.Trans Mountain proposal? (Ref.
Volume I I, Part 1, Page 2-16)
'.'@`4.',After the pipeline it in operation, what will be the origin of oily
water,drained from the storage'tanks at the Burlington tank farm?
What is the estimated quantity of oily water draine@ at the Burlington
tank farm? (Ref. Volume II, Part 1, Page 2-70)

A 2,000,000-gallon.reservoir for fire fighting water is proposed at
the Burlington tank farm. Where will the water be obtained to fill
this reservoir? If a well or wells are drilled to serve the tank
farm, how much water must be obtained to satisfy potable water require-
ments and to replenish the fire water reservoir? (Ref. Volume II,
Part 1, Page 2-76)

6. Will laboratory testing facilities be provided-at the Burlington -tank
farm for checking the.treated wastewater before discharge into Drainage
District No. 19 ditches? What monitoring and control will there be
of treated,runoff from the tank'farm site?.

7. Will the Burlington t .ank farm'be manned 24 hours a da. y, and what spe-
cial security precauti.ons (other than fencing) will be taken at the
Burlington tank farm?

Will there be any explosives or sources-of radiation at the Burling-
ton tank farm during the pump station, tank farm, or p.ipeline con-.
struction? (Ref...,VolumeI Page 3-3)

9. Corrosion, protection"for-the oil pipeline-will be facilitated by
using ground beds for the cathodic protection system. Where will
'these ground beds be positioned along the pipeline in Skagit County,
and what impact will., they have on the'surrounding land uses? (Ref.
Volume II, Part 1 Page 2-79)

10. The Trans. Mountain -Oil Pipeline Corporation does not have right-of-
way south of the Stackpole Road.in Skagit County. Have there been
any negotiations with property owners in,this'area for acquiring
right-of-way easements? Have'there been.any negot iations for acquir-
ing construction easements along the-entire,pipeline through Skagit
County?

-11. What flood volume is go Iing to be used'in designing the Skagit River
crossing? The 100-year flood volume used by the.Corps of Engineers
is 230,000 cubic feet.per second.

OBSERVATIONS

The first five miles of the proposed pipeline route through Skagit
County will require new right -of-way easements (from south county
line to Stackpole Road).

In Volume I, Page 2-80a, the Trans Mountain.report states that.-the
pipeline does not.pass through any-.of the city of Mount Vernon.
Recently annexed acreage to the south,of.the city takes in a portion
of the proposed pipeline route.

The,city of Burlington land use map shown as Figure 2-34e in Volume I
does not show the correct city limits.

The existing Trans Mountain pumping station wi.11 be dismantled and
relocated at the new pump station site.'@.

5. Major stream, crossings in Skagit County'are listed in Volume II, Part.
.1, Page 2-47. There are two unnamed crossings. These crossings are.
School House Slough and Heggens Slough.

6. Major utility pipe''crossings in Skagit County are listed in Volume 11,
Part 1, Page 2-49. Two natural gas pipelines and one oil products
line arellisted, but the 36-inch and 24-inch city of Anacortes water
mains along Bennett Road at pipeline milepost 104.1 are not mentioned.
These pipelines are.shown in Section A-7 of the appendix,of this report.

7. The fire protection system for the tank f arm is discussed in Volume 11,
Part 1, Page 2-75.

8. Wells will be developed for providing the fresh water requirements at
the Burlington tank farm. (Ref. Volume II, Part 1, Page 2-76)

9. Measures will be taken to protect other metallic pipelines crossed by
the proposed Trans Mountain pipeline. (Ref. Volume II, Part 1, Page
2-79)

.10. The pipeline route'.through.the Skagit lowlan'ds passes through what
A map showing arche-
are considered archeologically sensitive areas.
olog,ically sensitive areas.is.shown in Volume II, Part 2, Section 3,
Page 3-399.

1.1. All water used to@hydrostatically test the pipeline and oil storage
tanks will be treated and disposed of in Canada. (Ref. Volume II.,
Part 2, Page 4-71)

12.'The report indicates-that major road cross'i.ngs'and railroad crossings
will be bored
and cased with a steel pipe larger than the diameter of
the oil pipeline., S.ec..ondary roads will, be bored or open cut and the
oil pipelineinstalled without a casing. ..(Ref. Volume II, Part 1,
Pages 2-110 and 2-111).

13. A geologic map of.Washin'gton showing fault lines in Skagit Valley is
shown in Volume II, Part 1, Page 3-10. 'Earthquakes in the Skag.,it
Valley area are.discussed on Pages,3-41 and 3-42.
1@4. The pipeline route in the southern part of the county passes very
c1ose to the Skagit River Delta bird and wildlife sanctuaries.

15. In Volume II, Part 1, Page 3-155 is a table showing discharge data
for major stream crossings. The Skagit River is s hown to have a
maximum discharge of 144,000 cubic, feet per second in the period
from 1940 to 1977.

16. It is estimated that 456 pounds of oi,l products per day will be lost
by evaporation from tanks, valves, seals, and pipeline equipment at
the-Burlington tank farm (Ref. Volume II, Part 1, Pages 4-33, 4-34
and 4-35). These emissions are compared with a net reduction in
emissions due to fewer oil tankers calling at the March Point refin-
eries.

17. The report indicates that the.Friday Creek pipeline crossings will
probably aggravate existing water quality problems, which include
low summer flows, high water temperatures, and siltation. (Ref.
Volume II, Part I-, Page 4-85),

.18. Volume II, Part 1, Page.4-149 has a table showing peak construction
employment in Skagit County.at 399 workers. Of this, 104 will be
non local workers and 295 will be local workers.

.19. Volume H, Part 1, Page 4-157 has a table showing estimated sales
tax revenue.from construction. Skagit-County is estimated to receive
$141,000 in sales tax revenues.

20. Volume II, Part 1, Page 41-1.56 has'a table showing the estimated annual
property tax liability of the Trans Mountain project. It is shown
that Skagit County would receive approximately $4 million annually
based on 1979 average taxes.

Volume II, Part 1, Page 4-292 has a map showing potential structural
damage from a Burlington storage tank explosion.. It indicates that
general light structural damage could occur.within 2,200 feet of the
tank farm. This would include. portions,of SR-20 as well as a sUbstan-
tial portion of the Skagit'Regional Airport.

22:

APPENDIX

A-1 W. Beck and Associates Report

A-2 Pipeline Route Maps

A-3 Plan and Profile of Proposed Skagit River Pipe Crossing

A-4 Plan and Profile of Proposed Samish River Pipe Crossing

A-5 Typical Field Tile Drains Plan and Profile

A-6 Skagit County Public Works Department Letter

A-7 City of Anacortes Letter

A-7a City.of Mount.Vernon Letter

A-8 Dike District No. 1 Letter

A-9 Dike District No. 3 Letter

A-10 Continental Telephone of the Northwest Letter

A-11 Photographs

A-12 References and Interviews

R. W BECK AN DAsSOCIATES

ENGINEERS AND CONSULTANTS

PLANNING GENERAL OFFICE
DESIGN TOWER BUILDING SEATTLE, WASHINGTON
RATES 7TH AVENUE AT OLIVE WAY 206-622-5000
ENVIRONMENTAL
ECONOMICS SEATTLE, WASHINGTON 98101
MANAGEMENT 206-622-5000

FILE NO. WW-1577-ZZ1-MX April 29, 1981
6B

Leonard md Boudinot Inc.
Professional Engineers and Land Surveyors
P.O. Box 327, 612 East Fairhaven
Burlington, Washington 98233

Gentlemen:

Subject: Trans Mountain.Oil Pipeline
Review of Proposed Construction
Skagit County, -Washin&@on

Pursuant tothe terms of'our agreement for professional services,
we submit herewith a letter report with our. comments on the design and con-
struction aspects for that portion of the proposed Trans Mountain Low Point
Project located in Skagit County, Washington.

The basis for our comments relative to the design and construction
aspects of the proposed Project are from the following sources: (1) a brief
review of documents submitted by the Trans Mountain Oil 'Pipeline Corporation
to the Energy Fa2ility Site Evaluation Council, State of Washington, in appli-
cation for site certification of the Trans Mountain Low Point Project, filed
August 21, '1979, revised December 31, 1980; (2) a field reconnaissance of the
proposed route through Skagit County; and (3) a meeting with Trans Mountain
engineers in their Seattle office.

The documents submitted by the Trans Mountain Oil Pipeline Corpora-
tion, a total of six volumes, with the application for site certificat ion are
to be utilized in preparation of the Environmental Impact Statement for the
Trans Mountain Low Point Project by the Energy Facility Site Evaluation Coun-
oil, State of Washington. The probable environmental impacts of the Project
were addressed in considerable detail. The engineering aspects of-the Project
as addressed in the documents are of a preliminary nature. The scope of the
Project is defined by written text and preliminary drawings depicting many of
the facilities proposed for construction. The preliminary engineering appears
to have been completed in conformance with the American.Code for Pressure Pip-
ing, Liquid Petroleum Transportati on Systems (ANSI/ASME B 31.4). This code is
the standard of the industry and would further-be adhered to in preparation of
the final design of the proposed Project. The need for additional investiga-
tions and studies as a prerequisite to final design*and construction are

4-1
Seattle, WA Denver, CO Phoenix, AZ Orlando, Fl. Columbus, NE - Wellesley, MA Indianapolis, IN Minneapolis, MN Nashville, 7N Sacramento, CA

Leonard and Boudinot Inc. (2) April 29, 1981

addressed. Final design is not a prerequisite for' site certification of a
proposed oil pipeline project.

The field reconnaissance revealed no visible complications that
would indicate the need for an alternate routing from the standpoint of pipe-
line integrity. Minor adjustments in alignment may be necessary during final
design for the purpose of facilitating construction or. to achieve the best
possible location for pipeline integrity. South of the Burlington Tank Farm,
the route traverses farm and pasturelands. The land is flat and there is no
possibility of lateral earth movements (earthslides) that could result in dam-
age to the pipeline. North of the Burlington Tank Farm, the proposed pipeline
follows the route of can existing Trans Mountain oil pipeline. The existing
line has been in operation since the late 1950's and to this time there have
been no incidents to indicate that the soils along the route are not stable.
With proper attention to construction procedures, it is reasonable to assume
that a second pipeline can be constructed alongside the existing pipeline
without adverse results.

Generally, the pipeline route through Skagit County is not diffi-
cult terrain for the construction of an oil pipeline. There is the possibil-
ity of encountering groundwater in trenching operations, but with construction
in the fall of the year and the utilization of proper dewatering equipment,
this will present no problem. It is anticipated that pipe crews will be able
to lay from 1.0 to 1.5 miles of pipe per day once the operation is underway.
Construction crews will be organized to complete all operations as they prog-
ress across the County, starting with right-of-way clearing and completing
construction with right-of-way restoration.

The primary concern in locating aquatic pipeline crossings is to
select a site where the pipeline will be.stable. The pipeline can be placed
at a large number of locations along the length of rivers and drainage chan-
nels and satisfy this criterion. The determining factor becomes the routing
of the pipeline as a whole. By application of sound engineering practices
during site selection and final design, a stable pipeline can be achieved with
minimal adverse environmental impacts upon the strewn and the surrounding
area. To the best of our knowledge, public access will not be impeded and
aesthetic impacts will be minimal at any one of the crossings as proposed. It
must also be pointed out that*the Skagit and Samish River crossings will be
subject to review and approval by state and Federal agencies. The final
design for each crossing must meet their stringent requirements before con-
struction is allowed. It is also the prerogative of affected drainage dis-
tricts to exercise the'same requirement before allowing the crossing of drain-
age facilities.

Aquatic crossings by the oil pipeline in Skagit County consist of
the crossing of the Skagit and:Samish Rivers and the crossing of drainage
channels in the area south of the Burlington Tank Farm. The Samish River and
drainage channel crossings are not difficult crossings to construct. As pipe-
line construction is scheduled for the tall when streamflow is at a minimum,
the crossings will, in all probability, be made by open cut of the trench

Leonard and Boudinot Inc. April 29, 1981

crossing the channel. This method has two advantages from the standpoint of
construction. It is the most economical method for construction of an aquatic
pipeline crossing. It also affords the capability to.control construction
methods and operations which will result in a completed facility of known sta-
bility. The pipe under the streambed can be well founded to insure stability
of the installation and the channel can be restored to a condition equal to or
better than.existed prior to construction.
The Skagit Rivercrossing is 1 .ocated west of and to the south of
the City of Mount Vernon, approximately.1.5 miles north of the point of con-
vergence of the north and south delta channels. The.width of the crossing,
from levee to levee is approximately 1,450 feet, and Trans Mountain is propos-
ing to use directional boring for construction of the entire crossing from the
outside of 'the levee on each side of the river. Directional boring is a rela-
tively new technique for constructing installations of this nature.. Direc-
tional boring has, however, been utilized for many years in the oil industry
for drilling oil wells. With the-advent of new instruments and modifications
to boring machines, the method has been adapted for onshore construction of
aquatic crossings such as the.Skagit River. Trans Mountain engineers have
advised that this method has been successfully utilized several times in the
recent past for similar installations. They have also advised that subsequent
to preparation of the application for site certification, additional geotech-
nical investigations have been made at the proposed site for the Skagit River
crossing. The findings of these investigations indicate soils underlying the
river are of sufficient strength to successfully permit construction of the
proposed crossing by directional boring. In addition, the wall thickness of
the pipe will be increased at the river crossing, a check valve will be
installed on the north bank, and a remote controlled motor-operated block
valve will be installed on the south bank. The pipe strength has been in-
creased for added safety, and in the event of a breakin the pipe, the quan-
tity of oil spilled will be limited to that in the pipe under the river
between the two valves.,

By visual inspection, the site selected for the Burlington Tank
Farm appears satisfactory. The site is located on high ground above the delta
plain, and as such the underlying soils should be suitable for the proposed
construction. The site is now heavily-timbered. With controlled clearing,
the completed facility should be screened from view,within the immediate
area. It may be visible from locations at a distance from the site and from
areas of higher elevation.

Preliminary plans call for the.Tank Farm to be completely bermed on
-all sides to form an impoundment area of adequate size to contain all stored
materials. The entire impoundment area will be sealed on the inside to pre-
vent contamination of groundwater by the downward migration of oil from spills
or overflows within the area. Provisions will be made at the site for treat-
m
ent of surface water runoff prior to release into natural drainageways.

The low lying lands south of the Burlington Tank Farm appear to be
subject to high groundwater levels thoughout most of the year. This condition

Leonard and Boudinot Inc. (4) April 29, 1981

should be verified during final design and provisions made in the design to
prevent flotation of the pipeline and contamination of the' groundwater by
oil. The liquefaction characteristics of' native soils should also be investi-
gated and provisions made to provide negative bouyancy should it be deemed
necessary. There is also evidence that the pipeline crosses a fault in Skagit
County. The activity of the failt is unknown and will have to be determined
so that provisions can be made in the pipeline design to resist forces induced
in the pipe by the movement of the earth.- Negative bouyancy to prevent pipe-
line flotation can be provided by weighting the pipeline. Groundwater contam-
ination can be minimized by lining the trench with an impervious material and
constructing trench blocks at intervals along the pipeline. The possibility
of the existence of these conditions has been addressed in the site certifica-
tion application documents and are to be investigated in detail in the final
design. It is believed that all four of these conditions are of such conse-
quence as.to warrant review of the final design and supportive data by the
County for assurance that preventative measures have been provided where nec-
essary.
It should also be pointed out that the pipeline passes within 0.5
mile of the Skagit River intake for the City of Anacortes' water supply treat-
ment plant. Should oil enter the river-above the plant site, the water supply
for the City of Anacortes could be effected.

The proper design and construction of a pipeline, or any engineer-
ing project, are both essential to successful completion of the Project. Pro-
fessional and technical observations during construction assure that the work,
when accepted, is substantially in accordance with. the contract documents.
The responsibility for monitoring the pipeline construction is-not addressed
in the site certification application documents. Transcripts of Trans Moun-
tain answers to questions posed by the Department of Ecology do make mention
of the subject to the extent that (1) "Discussions are now underway with coun-
ties regarding construction monitoring. We anticipate that various state and
Federal agencies will monitor such things as archaeological resources, state
highway crossings and, of course, marine facility," and (2) "Trans Mountain
and its contractors will employ personnel for the exclusive purpose of insur-
ing that the pipeline and associated facilities are built to specification.
There would be special inspectors for x-ray of welds, tie-ins, backfill, etc.
In addition, an environmental inspector will be employed by Trans Mountain to
insure that special environmental mitigation measures are incorporated." This
is not a clear definition of who will be responsible for construction monitor-
ing. A combination of both would be satisfactory. It is advised that there
be an understanding pertaining to the division of these responsibilities prior
to start of construction.

In summation the comments stated herein concerning the construc-
tion of the proposed Trans Mountain oil-pipeline within Skagit County does
not, in our opinion, present any insurmountable problems that cannot be accom-
modated during final design and construction. It is recommended that the
County review the final design of the, Trans Mountain pipeline and insist on
adequate construction inspection and restoration. There is always the risk of

Leonard and Boudinot Inc. (5) April 29, 1981'

an oil spill occurring from a facility in spite of preventive measures. How-
ever, the impacts can be greatly mitigated when.the "state of the art" for oil
pipeline construction is applied to the design and during construction. This
is evidenced by the successful record of many miles of existing oil pipelines
throughout the United States.

If we can be of further assistance in answering any questions that
the Commissioners. may have, please advise.

Very truly yours,

R. W. BECK AND ASSOCIATES

Rai F. ScoffJjeld
Principal Engineer

RFS/bb

L E G-E ND

................... DIVIING ots-TPUCT ac:)UNOA@-W-y

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Ild
PROPOSED.
PIPE LINE
4,@, Ltvee
N
>

25 30 4F
Levee
LEVEE
0
SOOOII.
0
2 . "Britt
11 0
0 0
-j I )SIOQO
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(D X, -m#e Prop*%
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500, 0 50d 36'Pipaline
SCALI IN FEET OHW 10cO* 0 1000,
VICINITY MAP
CAsqr0nate: Lat. 48* 2 48: WM Coordinate: Lat. 48* 24' 44" N SCALE IN FEET
6
Lon. 12Z* 2 :46* W Lon. 1226 211 421 V

N. Levee 1450 ft. Directionolly Drilled S. Levee
920' '401 465

bor
0 H W El + 10'
NN,
Proposed 36 pt pe I I ne
0` 5d 100

VERTICAL SCALE PRESENT RIVER BOTTOM [LEY. - - 20'
0 30, PROFILE ALONG PIPELINE MAxlMUH SCOUR DEPTH . 4
1, R MAXIMUM SCOUR ELEVATION --24*
HORIZONTAL SCALE D. 0. T. REQUIRED BURIAL
BELOW SCOUR DEPTH 4
KAXIMUM TOP PIPE- [LEY. 40'

NO`rES
I .Proposed 36" pipeline to be installed br directional
drilling.

2. Approximate excavation volume 400 au- 749-

3 Excavated material to be placedon uplands.

071 OYB 2 006531

PURME: To transport cr-sde oil from storage area at Low Faint ?ROPOSED, SUBMARINE PIPELINE IN SKAGIT riiVER. NEAR MT.VERNON
in Washington to Inland refineries and to refineries
An Puget Sound. PIPELINE MILE Ic)I-6 (RIVER MILE 8.5)
DATUM: N.G.V.D. - 0.01 0929) COUNTY OF,SKAGIT STATE OF NA4M]*GTON
ADJACENT PROPERTY OWNERS: 5 Norman J. Brann APPLICATION IT TRANS MOU%YAIH OIL PIPE L!XE CORPORATION
H. F. bf. Kurth 4 Edna Stiodge HEET A.. OF !4. DATE: 10 April. IMO
k Ralph Oasterhoof 5 Edward Lundgren
'7 Feb. )c`t6l

Burllhgton@ 46
Proposed Northern R.R. -9
36"pipellne
03
40@ River ku J@
P7 0
OW j
50,

IL
X'Ing thli dwq. .4
LAT.' 480 31' 34" N 2 Pro 0sod
LON. 122022*07"W .11 .,1 36" ipelin+
VY
.C C4r@!.J-
0
j I
0
w Sam .8*11 RIJ.
Existing pipeline
Bearing ST03
E H w 1-@
y
Bailin
Slec. 13, T.35N, R.3E, WM. o ghom 20 Miles
in'
.,,Bur gton 2.5 Miles
14 ,13 Sam Bell Road
23'24 3 I.WQ =APQ ==Roo Feel
P I a n 600 0 Itoo VICINITY MAP
t F4 Fj F1
Feet
NOTES

1. Ppoposrb 36, PIPELINE TO BE RUN PARALLEL TO
Mud line) AND loo rT. rRom EXISTING 20- PIPLUNE
WITHIN THE CbC-3SIMG.

8.5,
F'roPosed 36*0 Pipalint Z.,iL-PROPERTY LINE
concrest. river weighl'o
4% R646150fY 10 Provide a 3. EXCAVATE 71EKH WITH IIACKHDE, DRAGLINE A CLAMSHELL.
MIRIMUnt 25# per foot negolive 4. APPROX. EXCAVATION W)tUK .
IIIA976ACY When pipe It engply, 600 C.y. CONSI%IING
Of SAND. GRAVEL. COBBLES OCLASIOKkL BOULDERS.
APPROX. BACKFILL VOLUME S70 c.y.
No scale Section thru french 5. EXCAVAXID FATCRIAL 70 BE VSIO FOR titctrILL.
EXCESS KAIERIAL 10 It PLACID ON UPLANDS.

4. *PLACE RIP RAP Dis NORTH I SOUIM BANK 10 A MINIKM
15, RIP rep. THICKNES@ OF 2 ft. W (WrO ACADSI@ VIO14 Or
40' 1 CONSTRUC71ON DISTURBED ARIA TO A MAXIMLjK 100 ft.
PROPOSED APPROX. RIP W VOLUMIE - 400 C.y.
5 0. H.w AIP- RAP tTyplOol)
Elav. I I PRESENT SL .OUGH BOTTOM ELEY. -+8,
8-5,cover MAXIMUM SCOUR DEPTH . 4.5,
50, MAXIMUM SCOUR ELEVATION - + 3.5'
D.O.T. itOUIRED BURIAL
BELOW SCOUR DE FTH . 4
Vo.M. 60' River Section along pipe line MAXIMUM TOP PIK CLEV. -0.5,

Hor.
Purpose: To transport crude oil from Low
Point, WA., to inland refineries.
Datum. N.G. V. D. : 0.0 * (IM) 071--OYS -2-006531
A&MC[Ill ftOPERIY OWNERS
Ac"rt Hills 3 [)via sammll SED SUWAAINE PIPELINE IN SAMISH RIVER. NEAR ALGER
Monic& O'bryan 4 Einer Kunuto PIPELINE MILE 111.7 (RIVER MILE 6.1)

COUIrly OF SKAGIT STATE Of WASHINGTON
APPLICATION NY 7RARS MCIMAIN OIL PIPE LINE CORPORATION

WET Of DATE: 10 April, 1990
REVISED: ',0MCir.M61
40' P, Rop"'o
0. H.W III P -RAP ITypl..I)

over

TYPICAL FIELD TILE DRAINS
PLAN

0 0 0
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- ---- ---- - -

TYPICAL FIELD DRAIN PROFILES

SKAGIT COUNTY PUBLIC WORKS DEPARTMENT
County Administration Building - P.O. Box 396 Mount Vernon, WA 98273

W. Eugene Sampley. P.E. Judith A. LaFollette John B. Ensley Jack C. Rafter, P.E.
Director Asst. Director Asst. Director Asst. Director
Permit Center Operations Engineering
(206) 336-9400 (206) 336-9410 (206).755-9531 (206) 336-9400

April 23, 1981

Leonard and Boudinot, Inc.
P. 0. Box 327
Burlington, WA 98233

Re: Proposed Trans Mountain Oil
Pipeline

Dear Bob:

The following is a list of our comments pertaining to the above referenced
project.

1. Since this pipeline crosses several county roads, we should alert the
pipeline company of the following:
a. Roads that can be.open cut.
b. Requirements for repairing roadway.
c. Road closure procedure.
d. Traffic control.
e. Permit franchise requirements.

2. The pipeline crosses Dike District I an 3 and they will have certain
requirements for going through their dikes.

3. The pipeline will also cross some drainage district ditches. I am sure
they will have some concerns.

4. We have always had good cooperation with Trans Mountain but we have had
problems with other line,owners. When the line is placed across open areas,
it is placed close to the ground surface and all requests to cross the line
have to be approved by the utility. This is fine if you assume the utility
will cooperate and negotiate an agreement mutually acceptable. This has not
always been the case and if they will not cooperate, the utility has

Leonard and Boudinot, Inc.
April 23, 1981
Page 2

unreasonable control of land use on and across their easement as well
as the adjoining property.

Very truly yours;
W. EUGENE SAMPLEY P.E.
Public Works Direct

BY: JACK C. RAFTER, P.E
Assistant Director of
Public Works

JCR:bjs

ClrrY OIFAT,,,TACOHrr]ES,WINSIIII@-lcxrrol*.q
98221
April 17, 1981 too

Mr. John Leonard.
Leonard & Boudinot, Inc.
612 East Fairhaven
Burlington, WA 98233

RE: Trans-Mountain Pipeline

Dear John:

Enclosed are utility maps showing the'area where the proposed Trans-
Mountain Pipeline will cross the City's 36" and 24" transmission lines
in the vicinity of Bennett Road and Memorial Highway.

This letter also will acknowledge our ineeting with you of April 15,
1981, to discuss possible problems.and/or solutions for the proposed
crossing. I would like to offer the following comments with regard to
the proposal:

1. In reviewing the proposed project with you and considering
the location of the pipeline in regards to the river, river
dikes, and the@Cityls intake structure, it appears that a
possible oil spilifrom a break in the pipeline would not
become a major problem to the City.

2. An area of concern is possible electrolysis and deterioration
of our pipelines from bein
ltin close proximity to the Trans-
Mountain lines. 'This @4ou be especially true if Trans-
Mountain protects their pipelines with a cathodic protection
device. Even the close proximity of the pipelines, while of
similar materail, could set up possible differences in
electrical potential. I would request that upon completion
of the project (assuming it is built) that Trans-Mountain have
a recognized corrosion engineer or engineering firm test the
potential between the pipelines and provide a letter to my
office assuring the City that no electrolysis potential exists
or if it does exist what measures will be taken to mitigate
the.problem.

3. Another concern that we have is with puncturing of our water-
lines during the installation of the Tran,s-Mountain line.
Both the 24" and 36" pipelines operate at pressures between
150 and 180 PSI and.provide water to three cities including
the City of Anacortes, two oil refineries, and NAS Whidbey on
Whidbey Island. Prior to making.the crossing, we would require

ADMINISTRAT ION FIRE DEPARTMENT POLICE DEPARTMENT PUBLIC LIBRARY. MUSEUM OF HISTORY
P'0. BOX 547 1011 112TH STREET 1011 12TH STREET 1209 9TH STREET 1305 8TH STREET
(206) 293-5171 (206) 293-5171 (206) 293-5171 (206) 293-2700 (2 06) 2 93 -5 171

Mr. John'teonard
April 17, 1981
Page 2

that the exact depth of both pipelines.be determined by physical
excavation of the lines. A representative of the City's Public
Works Department is to be present when'theexcavation is made. City
personnel will physically locate the horizontal alignment of both
pipelines.

I hope the above and the enclosed provide you with the information
necessary to proceed with your investigations. If you have any
questions or require additional data or wish to.discuss the project
further, please let me know.' Any new information which you might
receive or additional progress on the project, I would be interested
in knowing.

.Sincerely yours,

CITY OF ANACORTES

David M. Ford, Jr., P.E.
Director of Public Works

DMF:sg

Enclosures

cc: Robert Olander
Bruce Bell

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RUTH E. GIDLUND. MAYOR
MICHAEL WOODMANSEE. CITY TREASURER

DON SEMRAU. CITY ENGINEER
City of LARRY MOLLER. CITY ATIO-EY
ount RONALD MAYNOCK. SU,LDING .11ICIAL

Post Off ice Box 809 ernon, Washington 98273 Telephone 336-6585

May 18, 1981

Leonard & Boudinot, Inc.
612 East Fairhaven Avenue
Burlington, Washington 98233

ATTN: Bob Boudinot
RE: Trans-Mountain Oil Pipeline'

Dear Bob:

This letter is to confirm our conversation of April 13, 1981, concerning your
review of the E.I.S. for the proposed Trans-Mou.ntain Pipeline.

The pipeline as proposed would include approximately 750 feet in length through
property owned by the City of Mount Vernon and recently annexed to the City.
Olympic Pipeline also has a pipe within an easement over this City property.

You mentioned the construction plan includes double ditching through agricultural
property. Said City property is in agricultural use and will most likely remain
in this use. We would most certainly be interested in preserving the agricultural
topsoil. The City property is now leased to a farmer for cropping, so any proposed
construction wil.1 have to be preceded by an agreement for crop damage.

As I understand it, there are.no detail design pl ans available at this time, however,
the proposed minimum depth to'the top of the pipe is to be 40". This depth would
be acceptable.

The City wishes to use this property for municipal sludge disposal so we will be
concerned about backfill of the pipeline trench as.that might relate to ground water
quality and leachates.

Sorry to be so slow in sending you this letter. It was an easy one to set aside
and you did not keep calling me.

Sincerely,

Don Semrau, PLS & PE
City Engineer

DS:ch
oun'
)9 ;ern@i

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William A. Roozen, Commissioner
Dike District No. 1
1599 Beaver Marsh Road
Mount Vernon, WA 98273
April 21, 1981

Mr. John Leonard
Leonard and Boudinot, Inc.
P.O. Box 327
Burlington, WA 98233

Reference: Trans Mountain Pipeline

Dear Mr. Leonard:

This letter is to reiterate the concerns we.expressed at our meeting
of April 15, 1981, with you, Robert Boudinot, and Dike District No. 1
Commissioners, Bill Roozen, Tom Shane, and Robert Dean. We are very
concerned that residents in our Dike District are protected at all
times from any failure or disruption of the dikes'along the Skagit
River. We would like Trans Mountain Oil Pipeline Corporation to be
put on notice at this time that we will impose certain requirements
to protect our dikes and that we have the following questions for
which we request an answer.

1. Question: Why can't Trans Mountain Oil Pipeline Co'rporation
use the same right-of-way that Olympic Pipeline uses, thereby
having only one right-of@way through the county rather than
two?

2. Question: How far back from the outside of the dikes will.
the boring procedure take place? The cross section indicates
drilling from edge of dike to edge of dike., This could indan-
ger our dikes.

3. Question: What i s the name, address, and office phone number
of the chief executive officer of Trans Mountain Oil Pipeline
Corporation?

4. In our opini on steel baffle plates around the pipe should be
installed at each.end of the pipeline crossing. If baffles
are not proposed, we would like a full explanation.

5. If our dikes are cut for any reason, we will demand that the
opening not exceed a 48 hour period.

Mr. John Leonard
Page 2
April 21, 1981

6. If the dikes are cut, we will require that a D-8 bulldozer
or equal in good condition be at the site'one day prior to.
the dike opening, all during the operation,.and one day
after the dike cut.
7. If the dikes are cut, the dozer operator shall' be available
on a one hour call basis for one day prior to, during, and
one day after the dike opening.

8. The dike will be repaired with material a nd construction
conforming to State of Washington specifications, including
96 percent compaction and a clay core.

9. Any riprap disturbed will be replaced with two foot diameter
or greater riprap rock choked.with two inch crushed rock.

10. The surface of the -disturbed dike will be covered with ade-
quate topsoil and seeded with pasture mix at 20 pounds per
acre.

11. The Dike District mus@t have hold.harmless agreement from the
Trans Mountain Oil Pipeline Corporation and the pipeline
contractor or contractors.

12. If a dispute arises between Trans Mountain Oil Pipeline Corpo-
ration and Dike District No. 1, Trans Mountain Oil Pipeline
Corporation shall agree to pay all-legal fees for the litigation.

13. The Dike District will have a professional engineer inspecting
all construction work in the vicinity of the river crossing.
This engineering time will be paid for by Trans Mountain Oil
Pipeline Corporation. It is also to be emphasized that the
Dike District will choose their inspecting engineer.

The above points should not be considered our only concerns. .I am sure
that additional points will be 'considered as your design proceeds.

In summary, Dike District No. 1 is not looki 'ng for any compensation due
to this project, but are seeking the total protection for the people
within the Dike District. This is the job we are charged with and we.
will do our utmost,-.to,-.fulfill our responsibility.

Sincerel
X A

Wil am Roozen
Dike District Commissioner

Richard Smith, Commissioner
Dike District No. 3
1849 Dike Road
Mount Vernon, WA 98273
April 24, 1981

Mr. John Leonard
Leonard and Boudinot, Inc.
P.O. Box 327
Burlington, WA 98233
Reference: Trans Mountain P.ipel'ine

Dear John:

.Thank you.for the meeting with myself and Mr. Olson re.garding the Trans
Mountain Pipeline route through our Dike District No. 3. From our past
experience with other pipeline construction projects through our district,
we are quite familiar with the problems that the construction.of this
large pipeline will encounter. I would.like to point out the followi.ng
concerns:

1. Regardless of the method of construction across the Skagit.River,
whether it be drilled or open cut, we will require two see,page
barriers within our dike area on the pipe. If the pipelin'e is
drilled under the river as proposed, there is no way of knowing
the final diameter of the hole excavated under the dike, so pipe
must be exposed and barriers installed.

2. We note from the plansIthat the pipe is not very deep under the
dike and may need to be deeper at that point.

3. There is a surface crust on the soil through this general area of
5 to 6 feet, below which you will encounter'quicksand. Any exca-
vation within that quicksand area is extremely difficult and
causes large cave-in areas. Olympic Pipeline encountered severe
difficulty crossing underneath Old Highway 99 at the time they
constructed their pipeline.

4. We would recommend the pipeline be routed next to the railroad
between Conway and the Stackpole Road.

5. At Fisher Slough, we wish to point out that the pipeline must be
quite deep under the bottom of the slough, since maintenance of
that slough requires use of a drag line for excavation of sedi-
ment. We want the'pipeline deep enough to allow that maintenance
excavation to continue.

6. Trans-Mountain Pipeline must be aware that crossing Fisher Slough
will require working within the quicksand area below the surface

Mr. John Leonard
Page 2
April 24, 1981

crust which will probably pose more difficulty than is expected.
Depending upon the success of that boring operation, we may
require that seepage barriers beinstalled on each side of the
slough crossing.

7. We do not want above ground structures on any of the dikes.

8. There shall be no construction at the-Fisher Slough crossing or
the Skagit River prior to June 15 or after October 15. It is
very important that the integrity of this dike be maintained
at all times during the period of potential flooding.

The foregoing items are the main concerns which come to mind a t this time
and should not be taken as our only items of concern. Prior to any con-
struction at Fisher Slough or the Skagit River, the proper agreement must
be prepared and signed by our district commissioners and the Trans Moun-
tain Pipeline Company. We do not look forward to having this pipeline
crossing our farms within the district, but we realize that other routes
out of the farmland are*probably impractical.

Sincerely,

Richard Smith

ct, Contirwntal Telephorle
of the Northwest

Engineering Department
P.O. Box 579
Mount Vernon, Washington 98273

April 24, 1981

Leonard and Boudinot Inc.
612 E. Fairhaven Ave.
Burlington, Wash. 98233

Attention Bob Boudinot

Gentlemen:

our company suggests that most conflict with our facilities would be avoided
if the proposed Trans-Mountain pipeline-was at a minimum 4811 depth

It appears roughly that the line may cross our cables in about ten locations.
There may also be several poles requiring relocation.

I hope this information may be of use. Again, thanks for the advance notice
'of the project.

Sincerely,

Bob Knight
Dist. Engineering mgr.

BK/pa

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P-.1 Dike District No. 3. dike along Fisher Slough Mp 95.1 P-2 Fisher Slough MP 95.1
P-3 Fisher Slough MP 95.1 P-4 Drainage District No. 17 ditch southwest of 175 Conway
Interchange MP 96.3

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............

P-5 Culvert in Drainage District No. 17 ditch southwest of P-6 Drainage District No. 17 ditch west of 1-5 MP 96.5
1-5 Conway Interchange MP 96.3
P-7 Dike District No. 3 dike south of Skagit River MP 101 .4 P-8 Location of boring pit south of Skagi t Ri ver MP 101

991

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P-9 Skagit River crossing looking north MP 101.6 P-10 Skagit River crossing looking South MP 101 .7
P-11 Burlington tank farm site looking west from Ovenell P-12 @urlington tank farm sit t south of Ovenell Road
Road MP 106.0 left of road in picture@ OL

.4 M IR,

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- - - - - - - - - -

27ij

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'.1 . . . . . . . . . . . . .
.VIX

P-13 Drainage District No. 14 ditch looking west from P-14 Allen Elementary School MP 110.3
Avon-Allen Road MP 109.3
P-15 Existing 20-inch pipeline right-of-way north of P-16 Existing 20-inch pipeline right-of-way looking
Bell Road MP 110.8 south from Bow Hill MP 111.8

. . . . .......

-ItY

REFERENCES AND INTERVIEWS

1. Skagit County Public Works Department: Meeting.with Mr. Jack
Rafter, Assistant Director of Engineeri,ng, March 27, 1981

2. City of Mount Vernon: Meeting with Mr. Don-)Semrau, C ity Engineer,
April 15, 1981

3..City of Anacortes: Meeting with Mr. Robert Olander, City Manager,
and Mr. David M. Ford, Director of Public Works, April 15, 1981

4. Port of Skagit County: Meeting with Mr. Daniel O'Donnell, Manager,
April 28, 1981

5. U.S.D.A. Soil Conservation Service: 'Meeting with Ms Peggy Olds,
District Manager, April 22, 1981

6. Trans Mountain Oil Pipeline Corporation: Meeting with Mr. D.
Trevor Durrant, April 9, 1981

7. Department of Ecology: Telephone.conversation with Mr. Steve West,
April 10, 1981

8. Skagit County Public Utility District No. 1: Meeting with Mr. Jack
Doty, Manager, April 27, 1981

9. Dike District No. I:. Meeting with Mr. William Roozen, Mr. Robert
Dean, Jr., and Mr. Tom Shane, April 15, 1981

10. Dike District No. 3: Meeting with Mr.. Richard Smith, Commissioner,
April 23, 1981

11. Drainage District No. 14: Meeting with Mr. Roger Knutzen, April 27,
1981

12. Drainage District No. 17: Phone conversation with Mr. Charles
Waltner, April 20, 1981

13. Drainage District No. 19: Meeting with Mr. Nick Aarstad and Mr..
Harold Abbott, April 21., 1981

14. Skagit County Utility C oordinating Council: Meeting with utility
companies at Coordinating Council regular meeting, April 23, 1981

15. Meeting with Mr. Dennis 04Brien, private property owner, April 28,
1981

JOAA rOASTAL SERVICES CTR LIBRARY
3 6668 14112793 8