20141121-0013 FERC PDF (Unofficial) 11/21/2014

C TED

ED

(g
DN

II 7

DO

DDDNEEt+

MEMORANDUM
TO

CD
DCI
CD

I CT'.

Public File

Docket No. CP13-193-000

'" ul
T

FRONI

Gertrude F. Johnson
OEP/DG2E/Gas 4

DATE

November

SUBJECT

Record

12, 2014

of Call

12, 2014, Gertrude Johnson and Danny Laffoon (FERC staff) joined, via
conference call, the PHMSA meeting with Excelerate Energy L.P. (Excelerate) about the
Aguirre Offshore GasPort Project. Participants in the meeting/conference call are listed
in the attached table.
On November

The meeting focused on the specific details regarding the Aguirre Offshore GasPort
Project subsea pipeline design for compliance with PHMSA's regulations in Title 49 of
the Code of Federal Regulations, Part 192. Kenny McGeachie (Excelerate) led the
discussion beginning with the pipeline riser at the shore approach, explaining the
additional protective measures for the riser as it would be near the loading dock for the
oil barges. The subsea pipeline leading up to the shore approach would be lowered 3 feet
below the natural sea bed with concrete matting. The remainder of the pipeline route
would be lowered 3 feet below the natural sea bed with concrete coating in areas that are
less than or equal to 12 feet of water depth. All other areas greater than 12 feet of water
depth, the concrete coated pipe would be lowered to the natural sea bed. Excelerate
plans to lower the pipeline by diver-guided hand jetting. These details are the same as
those discussed during the November 6, 2014 conference call between FERC, PHMSA,
and Excelerate (record of the call can found in Docket No. CP13-193).

Mr. McGeachie continued to explain the planned pipeline design from point of inflection
3 to 2, crossing the Boca del Infierno and a sensitive coral area. Excelerate is planning to

CD

20141121-0013 FERC PDF (Unofficial) 11/21/2014

lay the concrete coated pipeline on the seafloor to minimize direct impacts on the
sensitive coral species, along with a combination of anchors and grout bags for protection
and stabilization. Steve Nanney (PHMSA) had questions particular to stabilization of the
pipeline to account for offshore weather events, particularly on the design for stability
and buoyancy from weather events and currents along/over pipeline. Excelerate and
PHMSA will continue the discussion on the appropriate measures for protection and
stabilization of the pipeline around the Boca del Infierno.

Mr. Nanney requested an explanation for why a horizontal directional drill (HDD) is not
proposed for the route crossing the Boca del Infierno. Excelerate stated that the focus is a
pipeline proposal that both meets PHMSA regulations and minimizes to the extent
possible direct impacts on the coral. Excelerate also mentioned that it has filed
information with FERC concerning the potential impacts from an HDD in the Boca del
Infierno. Gertrude Johnson stated that the current information filed by Excelerate on the
HDD is not sufficient to discount the feasibility of an HDD. Ms. Johnson advised
looking at other pipeline applications filed with FERC containing proposals to install inwater HDDs for the appropriate information to file with FERC on the feasibility of an
HDD. Ms. Johnson stated that an HDD through the Boca del Infierno would alleviate the
primary concern from the National Oceanic and Atmospheric Administration regarding
impacts on the coral species in this area. Mr. Nanney and Doug Catchot (Excelerate)
discussed Mr. Nanney's suggestion on researching other contractors, such as Michels
Corporations, for feasibility analyses of an HDD through this area. Mr. Catchot stated
that it's not possible for a contractor to ensure with certainty that there would zero risks
from an HDD installation. Ms. Johnson agreed but maintained that FERC staff cannot,
with the current information filed, discount implementation of an HDD crossing the Boca
del Infierno.
Mr. Nanney mentioned that Excelerate's Operations and Maintenance (OAM) Procedures
include future operational subsea inspections for pipeline movement.

Ms. Johnson requested clarification on whether the subsea pipeline would be "lowered"
or "buried." Mr. Catchot clarified that divers would hand-jet the sediment with a suction
hose and would replace the suctioned sediment over the pipeline. Mike Trammel added
that Excelerate is in the process of revising the installation procedures filed with FERC as
non-public appendices to its October 20, 2014 into a public version and that is in
layman's terms.
Mr. Nanney requested that the pipeline drawings submitted to PHMSA contain the
information he'd noted on his drawings in order for PHMSA to review of the pipeline
design. Excelerate agreed. Ms. Johnson added that Excelerate should delay filing its
response to FERC staff's November 4 Environmental Information Request until it has
reached concurrence from PHMSA on its pipeline design.

20141121-0013 FERC PDF (Unofficial) 11/21/2014

Mr. Nanney also requested review

documentation

of shipping

and notice to mariners in the area with

from the appropriate agency.

In a subsequent conversation on November 17, 2014, Mr. Nanney stated to Ms. Johnson
that the pipeline drawings submitted to PHMSA should include station numbering to
identify the locations where matting would be installed over the pipeline. Excelerate
agreed to include station numbering for the matting locations in a phone conversation on
November 18, 2014 between Ms. Johnson, Mr. Trammel, and Buck Booth.

20141121-0013 FERC PDF (Unofficial) 11/21/2014

IVAME
Steve Nanney

Meeting Participants
COMPANY
Department of Transportation, Pipeline and
Hazardous Materials Safety Administration

Ivelisse Sanchez
Daniel Bustos
Greg Ruhl
Jerry Landry
Doug Catchot
Emily Dondzila
Gertrude Johnson

(PHMSA)
Excelerate Energy L.P. (Excelerate)
Excelerate
Excelerate Energy L.P.
Puerto Rico Electric Power Authority
Excelerate
M&H
M&H
Excelerate
Excelerate
(Federal Energy Regulatory Commission)

Danny Laffoon

FERC
FERC

Kenny McGeachie
Mike Trammel

Buck Booth

20141121-0013 FERC PDF (Unofficial) 11/21/2014

Document Content(s)
13691580.tif..........................................................1-4