Town Sends Residents’ Pipeline Questions to Kinder Morgan

Following Kinder Morgan’s June 18 information session, the Town released a list of questions local residents hope to see the energy infrastructure company answer clearly.

Many of the questions address concerns about the safety of the proposed pipeline, one asking Kinder Morgan what its safety record is.

At the information session, Cherylann Pierce of 23 Mayflower Drive asked a representative for the company what the “incineration zone” for the pipeline would be.

Lucas Meyer, public affairs consultant for Kinder Morgan, said at the public meeting “incineration zone” is not an industry term.

The term incineration zone is used in material presented by opposition group New Hampshire Pipeline Awareness, which maps a 1,000-square-foot area on either side of the proposed pipeline that would be affected in a worst-case event.

“The rupture of a high-pressure natural gas pipeline can lead to outcomes that can pose a significant threat to people and property in the immediate vicinity of the failure location. The dominant hazard is thermal radiation from a sustained fire, and an estimate of the ground area affected by a credible worst-case event can be obtained from a model that characterizes the heat intensity associated with rupture failure of the pipe where the escaping gas is assumed to feed a fire that ignites very soon after line failure,” according to a report prepared by C-FER Technologies in 2000, funded by the Gas Research Institute.

According to the report, which details a model for sizing high consequence areas associated with natural gas pipelines, Federal code mandates increased wall thickness to reduce the corrosion and mechanical damage risks in densely populated areas, and assumes additional protection in areas populated by people with limited mobility, such as day care centers, senior homes and prisons.

Among the questions residents submitted to the Town, to be passed along to Kinder Morgan, is how the company would handle construction of the pipeline at the West soccer fields.

“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 the 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,” Kinder Morgan wrote in response to several questions the Londonderry Times submitted to the company last week. “There is no regulation that defines the setback from athletic fields.”

Another resident asked if Kinder Morgan can guarantee that the children playing on those fields would always be completely safe, and if not, why they could not make that promise.

Kinder Morgan responded, “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.”

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.

“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. We also work closely with developers and home builders, if possible, to determine where homes, businesses and developments are planned,” Kinder Morgan wrote. “Our typical final permanent right of way is 50 feet, with 25 feet on each side of the pipeline centerline.”

Additionally, Kinder Morgan wrote the design for the pipeline includes safety features that increase with population density and land usage along the pipeline, including extra wall thickness in more populated areas and additional depth of coverage in agricultural areas under active cultivation, as well as corrosion protective coatings.

According to a report on Kinder Morgan’s website, the company has maintained a three-year average of .03 gas pipeline onshore ruptures per 1,000 miles of pipeline between 2012 and 2014, compared with the industry average of .07 onshore ruptures per 1,000-miles of pipeline for the same period.

The company’s 12-month rolling average of reportable incidents going through May 31, 2015 is .35 incidents per 1,000-miles of pipeline. The industry average for such incidents for the same period is not available; but in 2014, Kinder Morgan reported .26 incidents per 1,000 miles, compared with the industry average of .44 incidents.

An incident, according to Kinder Morgan’s report, is defined as an event that involves a release of gas from a pipeline, or of liquefied natural gas, liquefied petroleum gas, refrigerant gas, or gas from a liquefied natural gas facility. The incident could result in one or more of the following consequences: death, personal injury necessitating in-patient hospitalization; estimated property damage of $50,000 or more, including loss to the operator and others, or both; unintentional estimated gas loss of 3 million cubic-feet or more; an event that results in an emergency shutdown of a liquefied natural gas facility; and an event that is significant in the judgment of the operator.

“Kinder Morgan’s incident rate is 30 percent lower than 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,” the company wrote.

In response to a resident’s question regarding industry “best practices” for determining safety margins for siting pipelines, Kinder Morgan said the company has a comprehensive pipeline integrity management program in place covering all of its pipelines, which 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,” Kinder Morgan wrote.

Other questions residents submitted to Kinder Morgan through the Town are the following:

• What New Hampshire body (if any) determines safety margins for siting pipelines?

• What Industry “best practices” (if any) have a bearing on determining safety margins for siting pipelines?

• Is the pipeline generally centered in the 400-foot easement that you refer to?

• When you site a pipeline, how far is it from the edge of that easement to the closest occupied structure?

• When you site a pipeline, how far is it from the edge of that easement to the closest residential property line?

• If the pipeline goes through in the projected route, will Kinder Morgan compensate property owners for loss of property value due to the pipeline; and will they pay for abutters to stay elsewhere while the pipeline is being built?

• How can Kinder Morgan safely go through a wetland?

• If the freeze level can be as deep as 5 feet, shouldn’t the pipe be placed that deep?

• What about frost heaves? How can we know that Kinder Morgan will prevent these from happening around their pipeline?

• How exactly is the tax calculated that is paid to every town?

Meyer said it will take about two weeks for Kinder Morgan to respond with answers to all the questions, which Town Councilor John Farrell said at the information session would be posted on the Town’s website at

The State Legislature is also working to address some of the concerns raised in the questions residents asked.

House Bill 572, for example, clarifies the amount of damages to be awarded to the owner of a property acquired by eminent domain, requires rules be adopted governing the siting of high pressure gas pipelines and prohibits taking by eminent domain public or private conservation land.According to Kinder Morgan, Tennessee Gas Pipeline understands the overarching objectives of the State Legislature 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.“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,” the company wrote. “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.”

State Sen. Sharon Carson and State Rep. Doug Thomas, both Londonderry Republicans, attended the information session and urge residents who have questions or concerns about the project to contact them.Kinder Morgan’s answers to the questions submitted by residents and the Londonderry Times were extensive. To ensure residents have the opportunity to read the complete responses, they have been posted on the Londonderry Times website at or click here .

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