The following is a list of questions the Londonderry Times submitted to Kinder Morgan related to the company’s proposed construction of a natural gas pipeline through Londonderry as part of the Northeast Energy Direct Project, with Kinder Morgan’s complete answers.
Residents have asked, how will Kinder Morgan handle construction of the pipeline at the West soccer fields?
We seek to site pipelines so that they will have the least possible effects on homes, businesses, structures, buildings, schools, hospitals, senior citizen facilities, churches and other facilities; including sports complexes, as well as cultural and historical sites, sensitive habitat areas, native American sites, archaeological sites, areas with endangered species, for example, and any other special sites identified during the course of the pre-filing and permitting process.
We have a very good understanding of the various distances involving the sports complex fields in relation to possible pipeline right of way. As currently proposed, the pipeline centerline would be situated between two fields and be co-located with powerline through this area, with the northerly sports field located approximately 222-feet from the pipeline centerline and the southerly field approximately 187-feet from the centerline. There is no regulation that defines the set back from athletic fields.
Can Kinder Morgan guarantee the children playing on those fields will always be completely safe, and if not, why can’t they make that promise?
What we can guarantee is the following:
Kinder Morgan and Tennessee Gas Pipeline, a Kinder Morgan company, are committed to public safety, protection of the environment and operation of our facilities in compliance with all applicable rules and regulations. It is our goal to work openly and cooperatively with all stakeholders regarding9NED environmental, health and safety issues and on proposed projects, such as Northeast Energy Direct (NED).
Regarding safety and safe operations, specifically, the majority of Kinder Morgan’s pipelines fall under the regulatory oversight of the Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department of Transportation’s Office of Pipeline Safety and the Code of Federal Regulations, Title 49 and applicable sections.
Here is a sampling of how the design and implementation of the NED Project will follow federal PHMSA regulations on pipeline safety and operation:
a. Design – Tennessee Gas’ pipeline design includes safety features that increase with population density and land usage along the pipeline. This includes: (i) extra wall thickness in more populated areas, (ii) extra wall thickness at road crossings, (iii) additional depth of cover in agricultural areas under active cultivation, (iv) corrosion protective coatings, and (v) cathodic protection facilities to protect against corrosion.
b. Testing – Tennessee Gas further X-rays 100 percent of all pipeline welds and pressure tests the completed pipeline with water at a pressure much higher than it will operate to ensure that it is properly built prior to being placed in service. It also inspects the pipelines internally before placing them in service to help ensure that any anomalies are identified and repaired prior to the line going into service.
c. Cathodic Protection – Tennessee Gas applies electrical current, known as cathodic protection, to the pipeline to prevent external corrosion from occurring and regularly checks the pipeline to ensure the protection is consistently applied. By applying the electrical current, the pipe is protected from pipe steel being removed by corrosion.
d. Encroachment – One of the most common causes of pipeline incidents is damage by a third party. We obtain an approximately 50-foot wide permanent right-of-way to distance third party construction activities from accidentally damaging our pipeline. This gives us room to safely operate and maintain the pipeline.
e. Tennessee actively participates in all applicable “One Call” programs to help prevent third-party damage. Tennessee will meet landowners and contractors to discuss excavation and marks all pipelines prior to excavation when provided with notification by state One Call programs. Depending on the location of the digging, Tennessee also will have a company employee on site to observe digging operations around its pipelines.
f. Monitoring – Tennessee Gas closely monitors pipeline operations, including line pressure and surveillance of the pipeline to detect leaks and protect against third-party damage.
g. Inspection – Tennessee Gas uses state of the art in-line inspection tools, known as smart pigs, to periodically internally inspect the pipeline in accordance with PHMSA requirements for potential damage, erosion or corrosion. Any damage or corrosion detected through this process is repaired or replaced.
We post our safety statistics online and currently outperform our peers on 35 of 36 safety measures. The data in this report represents the number of Department of Transportation (DOT) reportable incidents per 1,000 miles of Transmission and Regulated Gathering pipe that Kinder Morgan operates. It is reported using 12-month and three-year average rates, and compares Kinder Morgan’s performance to the industry average:
www.kindermorgan.com/content/docs/Gas_Pipeline_Incidents.pdf
System Operation Monitoring/Inspection
Pipeline operating conditions are monitored 24 hours a day, 7 days a week by personnel in control centers using a Supervisory Control and Data Acquisition (SCADA) computer system. This electronic surveillance system gathers such data as pipeline pressures, volume and flow rates and the status of pumping equipment and valves. Whenever operating conditions change, an alarm warns the operator on duty and the condition is investigated. Both automated and manual valves are strategically placed along the pipeline system to enable the pipeline to be shut down immediately and sections to be isolated quickly, if necessary.
Visual inspections of Kinder Morgan’s pipeline right-of-way are conducted by air and/or ground on a regular basis. The right-of-way is a narrow strip of land reserved for the pipeline. Above ground marker signs are displayed along the right-of-way to alert the public and contractors to the existence of the pipeline.
The leading cause of pipeline accidents is third-party damage caused by various types of digging and excavation activities. Kinder Morgan’s public awareness program is designed to prevent third-party damage to its pipelines. Additionally, the company is a member of numerous “call-before-you-dig” programs or “one-call” systems across the United States, which are designed to help the public, contractors and others identify the location of pipelines before excavation or digging projects to prevent damage to pipelines and protect the public.
Emergency preparedness and planning measures are in place at Kinder Morgan in the event that a pipeline incident occurs. The company also works closely with local emergency response organizations to educate them regarding our pipelines and how to respond in the unlikely event of an emergency.
The legislature recently passed HB572, a bill that requires rules be adopted governing the siting of high pressure gas pipelines. Would FERC overrule any rules adopted in NH? If so, would Kinder Morgan still try to adhere to those rules established by the State Legislature?
New Hampshire legislative officials, showing good stewardship for the citizens of the state, have determined that it is in the public interest for the state’s Site Evaluation Committee to establish criteria or standards governing siting of high-pressure gas pipelines, with the expressed aim of seeking to ensure that potential benefits are considered and adverse effects are avoided.
Tennessee Gas Pipeline understands those overarching objectives and will work not only through the Federal Energy Regulatory Commission permitting process, including both federal and state agencies, but also in recognition of New Hampshire’s objectives, as Tennessee Gas continues in the pre-filing process for the proposed Northeast Energy Direct pipeline project and agency permitting that continues.
We cannot speak for the FERC in terms of its view of the state action and its effects relating to the FERC process for natural gas transmission pipeline and infrastructure siting. The FERC will decide whether to grant the NED project a certificate of public convenience and necessity. It will also determine the route of the pipeline. These decisions will be made in accordance with federal laws and rules. To the extent that state rules conflict with federal laws and rules regarding natural gas pipelines, the federal provisions will govern.
Because the New Hampshire Site Evaluation Committee has not yet promulgated rules under the new statute, it is unknown whether those rules will be preempted by federal statutes or rules.
What Industry “best practices” (if any) have a bearing on determining safety margins for siting pipelines?
We have a comprehensive pipeline integrity management program in place covering all of our pipelines that includes inspections, testing and maintenance. NED will be designed, installed, operated and maintained in accordance with best industry practices on pipeline design, construction, installation, operation and maintenance and in compliance with federal safety and operational requirements for interstate natural gas pipelines. These standards and practices have been developed with the benefit of nearly 100 years of operating experience and increasing regulatory requirements.
Furthermore, Kinder Morgan’s incident rate is 30 percent lower that the interstate natural gas pipeline’s industry average (0.25 incidents per 1,000 miles over the last three years versus the industry average of 0.38 incidents per 1,000 miles). And, in 2014 alone, we spent more than $400 million on pipeline integrity management and maintenance programs.
We also follow requirements set forth under federal law (Code of Federal Regulations, Title 49 CFR, Part 192) on pipeline class locations and requirements under the Title and also apply our own stringent procedures on pipeline integrity management, including testing and inspection and maintenance.
When you site a pipeline, how far is it from the edge of that easement to the closest occupied structure? At the informational session, a representative for Kinder Morgan said some homes have been built right up to pipeline easements.
As we said in Response #1, we seek to site pipelines so that they will have the least possible effects on homes, businesses, structures, buildings, schools, hospitals, senior citizen facilities, churches and other facilities, including sports complexes, etc. We also work closely with developers and home builders, if possible, to determine where homes, businesses and developments are planned. Our typical final permanent right of way is 50 feet, with 25 feet on each side of the pipeline centerline.
Unfortunately, however, local/state permits, ordinances and state laws can govern and sometimes result in structures being built closer to existing pipelines and other types of buried utilities.