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Bradwood Landing Project

Bradwood Landing Project. WA Pipeline Segment Review. WA Pipeline Segment. All in Cowlitz County Connection to Williams Northwest Pipeline at Kelso, WA Based on Public Info in Project DEIS (Aug 2007 version) & Associated References www.ferc.gov/industries/lng/enviro/eis/2007/08-17-07-eis.asp

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Bradwood Landing Project

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  1. Bradwood Landing Project WA Pipeline Segment Review

  2. WA Pipeline Segment • All in Cowlitz County • Connection to Williams Northwest Pipeline at Kelso, WA • Based on Public Info in Project DEIS (Aug 2007 version) & Associated References • www.ferc.gov/industries/lng/enviro/eis/2007/08-17-07-eis.asp • Plus Non-internet Public Info Supplied by FERC

  3. Bradwood Project Overview

  4. WA Pipeline Segment • 30 inch Pipe • ~16.9 miles in WA (MP 19.4 - 36.3) • Grade - API SL-X-70 • MAOP = 1280 psig • Thickness • Class 1 / Class 2 = 0.458 in, Class 3 = 0.550 in • FBE External Coating • Designed for Pigging w Launcher/Receiver • Gas Not Odorized • Class Location Distribution Not Defined • Essentially All Pipe in WA, Class 1 or 2 • Minor Miles of Class 3 - 0.63 Miles • Mainline Block Valves Remotely Operated • MPs 0.0, 3.7, 18.8, 26.3, 31.7, 36.3

  5. HCAs on WA 30 inch* *Table from DEIS

  6. Potential for Frac-Outs during HDD of Streams What is the response to a frac-out, and how effective would it be if it takes 30 minutes? "Frac-outs" spewed more than 40,000 gallons of drilling lubricants and muds into Rock Creek, a salmon spawning stream in Oregon, during a recent pipeline installation

  7. WA Pipeline Landslide Areas • Table 4.1.4-3 of DEIS • ROW Crosses 31 Potential Landslide Hazard Areas of Concern in WA • DEIS Recommends • More Field Mapping to Develop “Final Pipeline Design Geotechnical Report” • Use of Automated Strain Meter Monitoring of Pipeline Segments • Pipeline Landslide Mitigation Effort Options • Reroute Pipeline • Bury Below Potential Earth Movement (i.e., HDD) • Stabilize Slope

  8. WA Pipeline Segment Approximate Elevation Profile* *Based on Data Estimated from DEIS Table 4.1.4-3 and Appendix B “Pipeline Location Map”

  9. WA Pipeline Concerns • Routing and Construction • 14,000+ Ft using HDD • Not All HDDs are Successful • Landslide Risks • Routing Important • Girth Welds Critical • 100% Nondestructive Girth Weld Testing/Record Retention Not Required in Federal Pipeline Safety Regulation • Girth Weld Nondestructive Testing Not Clear in DEIS • Strain Metering of Limited Value in High Hydrology Slide Areas • No Pipeline Can Take a Massive Earth Slide • ROW • Construction ROW Width 85 to 120 ft, Mostly 100 ft • Permanent Operational ROW Width 50 ft • Approximately 8 miles Follows Existing KB Pipeline • Avoid Past KB Problem Sites

  10. Trees on Rights-of-way • DEIS states that the company will replant trees within 5-15 feet of the pipeline in forested and wetland areas, and that such plantings will provide a nearly full canopy cover • DEIS states that property owners can not plant trees anywhere on the 50 foot permanent right-of-way. Why the apparent double standard?

  11. ROW Inspection Method? • If company plans to plant trees to provide a nearly complete canopy cover, how do they intend to inspect the pipeline ROW as per CFR 49 Part 192.705?

  12. Need for independent analysis of the need for this gas In the DEIS (pages 1-4,1-5, 3-2), FERC justified the need for this additional gas by referencing reports from the Northwest Gas Association (NWGA) and Energy and Environmental Analysis (EEA) Inc Who are these companies and are they a fair independent source for the government to rely on?

  13. The Northwest Gas Association (NWGA) is a trade organization of the Pacific Northwest natural gas industry. The NWGA's members include six natural gas utilities serving communities throughout Idaho, Oregon, Washington and British Columbia; and three natural gas transmission pipelines that transport natural gas from supply basins into and through the region.

  14. Energy and Environmental Analysis (EEA) Inc is a private consulting company. Their website (http://www.eea-inc.com/index.html) has this to say about their work: “Gas Market Scenario Analysis Construct Your View Of The Future EEA provides market projections that are based on your strategic planning assumptions.”

  15. Is this pipeline needed? Do multiple proposed pipelines serve the same function? Does anyone decide which one is needed and makes the most sense? Why put so many local communities through the expense of these multiple siting processes?

  16. Corporate Decision vs. Need? “Palomar Pipeline - A two-phased pipeline extension of Gas Transmission Northwest Corporation’s (GTN) interstate pipeline.ﾊ The first phase would connect GTNﾕs pipeline in Madras, Oregon to the gate station in Molalla. The second phase would continue this pipe northwest to NW Natural’s facilities near Mist, Oregon, positioning the project to handle an interconnect with a potential import LNG terminal on the Columbia River. Essentially, the pipeline would enable the company to further diversify beyond being served by a single interstate pipeline” Draft 2007 Integrated Resource Plan filed with WUTC

  17. What’s to Become of the KB Pipeline The DEIS makes it clear that the new pipeline will serve the Beaver Power plant. Does this make the KB pipeline and ROW obsolete? What will be done with it?

  18. Observations • Topography Merits Construction Methods in Excess of Federal Pipeline Safety Regulation • Need to Assure Construction Incorporates Prudent QA/QC • Routing - Final Geo Study! • Pipe Transportation • Welding • Pipe Laydown • Hydrotesting is Not a Girth Weld Test • Advise 100% Nondestructive Testing of Girth Welds with Records Kept for Life of Pipeline

  19. Use of Old Data to Determine Safety Concerns The DEIS used data from 1970-1984 to draw the conclusion that outside force damage was the biggest concern for these types of gas transmission pipelines. Newer data (1984-present) shows that corrosion is the the bigger concern.

  20. Proper Oversight Needed • Construction Phase Can Be a Weak Link in Pipeline Safety Regulation • WUTC Can Monitor this Critical Pipeline Phase • Interstate Agent of PHMSA • FERC Cannot Do This • Can Impose Additional “Safety” Conditions as a Requirement to Project Agreement • Final Pipeline Route May Be Slightly Modified • C-fer Circle Not Appropriate for PIZ Estimate • Where Does the Committee Go From Here?

  21. Possible Issues For Committee to Address • Construction Related Issues • Need for WUTC to do construction inspections • Greater clarity on seismic and landslides issues • Accuracy of current analysis • Use of strain gauges • What happens if HDD doesn’t work • 100% girth weld x-rays, and retaining documents for life of pipeline • 30 minutes response for frac-outs?

  22. Independent analysis of need • Need for gas • Competing pipelines for same gas • Right-of-way Issues • Justification for not following KB ROW more? • Trees on ROWs - • Private plantings vs.company plantings • ROW inspection method? • Replace/abandon KB Pipeline? • Use of old data to determine pipeline safety issues

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