VCE
The text of NYSEG/SVNG's response to the VT Agency of Transportation request for an evaluation of using the existing Vermont Railway Corporation rail bed as a route for the proposed natural gas pipeline. [This information is available to the public through the Freedom of Information Act.]

To: Mr. C. Allan Wright of VT. Agency of Transportation

From: Matt J. Cook, SVNG

Received: March 1, 1999


Southern Vermont Natural Gas Railroad Routing Evaluation


Proposal:

The Vermont Agency of Transportation requests that Southern Vermont Natural Gas (SVNG) investigate the possibility of utilizing the existing rail bed for the Natural Gas Transmission pipeline proposed to supply Bennington and Rutland Vermont with natural gas. The rail bed is currently occupied by rails operated and maintained by the Vermont Railway Corporation. The tracks are used occasionally for scenic tours and freight transportation. The AOT proposes that SVNG remove the rails and ties and install the 24 inch steel pipeline in their place.

Response:

SVNG has reviewed the rail bed as an option early on in the process of route selection. The total length of the railroad bed from the proposed plant site on the South end of the City of Rutland to the proposed plant site on the North end of Bennington is 54.3 miles. Comparing this to the length of the pipe if it were to follow the Electric Transmission lines/Route 7 corridor the length would be 59.8 miles. Although shorter in length, the railroad offers several challenges to be overcome in order to install pipe directly below the tracks. The following are the advantages and disadvantages of installing the pipeline under the tracks.

Advantages:

This would prepare the bed for replacement with track capable of handling high speed rail which if installed would provide improved rail service to the Southern portion of Vermont. This would utilize an existing disturbed right-of-way which would minimize the affect to Vermont Route 7. The railroad tracks pass through the two proposed power plant sites in Bennington and Rutland. This provides for easy termination of the pipeline at the two sites. The railroad is State owned. This means that SVNG would deal with one entity for permitting. The rail road alternative is shorter in distance than the other alternatives. The railroad is 54.3 miles while the shorter of the other alternatives is 59.8 miles.

Disadvantages:

Construction Issues:

The first and most difficult challenge is the width of the rail bed. Much of the rail bed is raised above the level of the surrounding ground along the tracks. In some cases the height of the raised bed is 10 to 20 feet higher than nominal grade. The width of the rail bed throughout is typically 20 feet. The difficulty is to perform all the operations necessary to construct within that space in a safe, least environmentally disturbing and most economic fashion. The width of most excavating equipment used to install 24" pipe is a minimum of 12 feet. The trench width in stable soil will typically be 4 feet, if unstable soil or large rock is found, the trench width could easily reach 6 to 8 feet. The problem arises as to what to do with the material (spoil) removed from the trench. This spoil should be placed on one side of the trench far enough away from the edge to prevent collapse. With a 4 foot wide trench centered on the 20 foot width bed, the remaining space for spoil is 8 feet Taking into account the space between spoil pile and trench, there is physically not enough space left to pile the spoil. Therefore, if placed along side the trench the spoil could fall down the rail embankments onto the ground below making retrieval and backfilling of the trench difficult. Ensuing processes such as pipe laying, pipe bending, welding and x-raying of welds would be hampered by the lack of space. The risk of collapsing the trench due to heavy equipment close to its edge is greater and if that occurs would require the reconstruction of the entire ballast.

Safety and Operating Issues:

The issue of safety of Southern Vermont's Natural Gas system is important. Typically rail services have a difficult time allowing pipelines within their rights-of-way let alone directly under the rails. Their concern is that of the integrity of the pipe and damage that could occur to that facility if a train derailment occurs.

Southern Vermont Natural Gas Corporation contacted Vermont Railway Company in Rutland Vermont to discuss the possibility of installing the 24" steel pipe under the tracks. Vermont Railways response was against this as an option. They believe that construction could do damage to the ballast that would be difficult to repair. They questioned the problems that would arise after construction and SVNG's need to access that pipe at a later date.

Vermont Railway Company utilizes the American Railway Engineering Association (AREA) Manual for Railway Engineering for its specifications. If Vermont Railway Company were to entertain this as a viable option, the pipe would have to be installed in accordance with the AREA guidelines for installing pipelines within railroad rights-of-way. Section 5.1.2 of these specifications state that "Pipelines laid longitudinally on railway rights-of-way shall be located as far as practicable from any tracks or other important structures. If located within 25 feet of the center line of the track or closer than 45 feet to the nearest point of any bridge, building or other important structure, the carrier pipe shall be encased or of special design as approved by the engineer." This means that along the entire length of tracks the pipe would have to be cased which would basically require the purchase of twice the amount of pipe for the entire 54.3 miles. Steel in steel casings is a- philosophy that the industry (oil, water and gas) has gotten away from because of corrosion concerns. It is understood that some casings may have to be installed along the length of the pipeline, but these smaller locations (road, railroad crossings) are easily managed with regards to corrosion control, than would be the entire length. Additionally, Section 5.1.5.2.3 states that, "Pipeline laid longitudinally on the railway rights-of-way, 50 feet or less from center line of tracks, shall be buried not less than 5 feet from ground surface to top of pipe." This would require 2 foot of additional cover over the pipe than what is necessary for construction in those areas outside of railroad property. This would result in additional spoil handling, greater environmental impacts and increased construction times.

Another concern is the stability of the rail bed after construction is complete. After installation of the pipeline is complete the trench is backfilled and compacted sufficiently to prevent settlement. Occasionally, even after the proper techniques are applied to this operation some trenches still can settle. Southern Vermont's Construction Specifications have provisions to reestablish to grade any of these settlements that may occur. It is possible however, that any trench settlement under the tracks due to the installation, could jeopardize the operation of a train along those tracks.

Having the pipe under the tracks would cause difficulty for the operation and maintenance of the pipe. Several times per year the pipe right-of-way is to be traversed to perform various patrols and surveys. Assuring safety of the maintenance personnel while the rail remains operational could be difficult for both Southern Vermont Natural Gas and Vermont Railway. Also problematic would be access to the pipe after construction. Tapping the pipe would require the rails to be lifted and an excavation made to expose the pipeline which would interrupt rail service for a period of time.

Environmental Issues:

If the pipe were to be installed under the tracks for the entire length there could be significant environmental impacts when compared to the other route alternatives. The railroad construction could impact 1.25 times more streams, 7 times more wetlands, 8.5 times more floodplains and 2 times more threatened and endangered species habitats than other routes. To install the pipe under the rail bed it would be necessary to acquire a minimum of 50 feet of new right-of-way parallel and adjacent to the rail bed. This would require approximately 250 acres of land. Taking in to account that approximately 75% of the bed is raised above surrounding ground level high enough that working along side the bed would not be feasible, it is reasonable to believe that some type of fill would have to be brought in to build a roadway along the railroad to construct along this route. Discussions with the Agency of Natural Resources indicates they would not permit any filling of wetlands for construction purposes. With the amount of wetlands along the tracks this could mean that construction along much of this route would be very difficult if not impossible.

Economic Issues:

Natural Gas is a fuel that competes with other fuels. However, natural gas is the only fossil fuel that is regulated by Federal and State governments. The regulatory bodies governing natural gas do not allow the cost of new installations (such as new franchises) to be absorbed by existing customers. Each new installation has to have the necessary revenues associated with it to pay for the cost of construction. Therefore, projects such as this one often are marginally economic.

The cost of constructing along other existing rights-of-way such as the highways and utility corridors in Vermont for this project are expected to be approximately $26,000,000. The cost of removing the track and installing the pipeline in its place can be expected to raise this cost to approximately $70,000,000 or 270% greater even though this route is shorter. This would overly burden the project to the point of no longer being able to support itself, and therefore it would not be constructed.

Conclusion:

In conclusion, SVNG believes that because all four decision criteria (Construction, Safety, Environmental and Economics) are compromised, installing-the transmission pipeline under the railroad tracks or within the railroad right-of-way throughout the majority of the Bennington to Rutland corridor, is not a viable option.

Copyright © 1999 Vermonters for a Clean Environment
Updated: Friday, October 1, 1999