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SAFETY ASSESSMENT OF
VIRGINIA NATURAL GAS’S SOUTHSIDE CONNECTOR DISTRIBUTION PROJECTAND
COLONNA’S SHIPYARD’S AND COMMUNITY’S SAFETY CONCERNS1
SUBMITTED TO THE CITY OF NORFOLK BY
RICHARD B. FELDER,FORMER DIRECTOR OF THE OFFICE OF PIPELINE SAFETY
AT THE U.S. DEPARTMENT OF TRANSPORTATION
AND
RICHARD E. SANDERS,FORMER DIRECTOR OF THE TRANSPORTATION SAFETY INSTITUTE
AT THE U.S. DEPARTMENT OF TRANSPORTATION
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TABLE OF CONTENTS
CURRICULUM VITAE
Richard Felder……………………………………………………………………………….. 3
Richard Sanders……………………………………………………………………………… 5
EXECUTIVE SUMMARY……………………………………………………………………………… 14
SAFETY ANALYSIS……………………………………………………………………………………… 16
SAFETY ASSESSMENT………………………………………………………………………………… 18
Pipeline efforts to exceed Federal Pipeline Regulations……………………… 21
Pipe Material…………………………………………………………………………. 24
Valve Spacing…………………………………………………………………………. 24
Cathodic Protection System…………………………………………………….. 24
Construction Inspection…………………………………………………………… 24
Periodic Inspection/Maintenance…………………………………………….. 25
Safety Oversight After Construction Is Completed…………………….. 25
CONCLUSIONS……………………………………………………………………………………………. 29
1Reference: Safety Assessment and Colonna’s Safety Concerns Deaver and Kuprewicz Final Version
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RICHARD B. FELDER
PIPELINE SAFETY AND REGULATORY LAW CONSULTANT
7378 EAST DEL ACERO DRIVE SCOTTSDALE, ARIZONA 85258
[email protected] 970-544-6798
Education: Cornell University Bachelor of Arts in Government 1968
New York University School of Law Juris Doctor 1972
Work Experience
Interstate Commerce Commission
I spent most of my government career at the Interstate Commerce Commission. Fresh out ofLaw School, I served eight years there advancing from Staff Attorney to Principal Attorney, toAdvisor to one Commissioner, then Chief of Staff to another Commissioner and finished byheading the office that was responsible for economic regulation of railroads, trucks, buses andbarges throughout the United States. My second stint included service as Head of the MotorCarrier Section and Deputy General Counsel in charge of regulatory development. Betweenthose two Senior Executive positions, I served a detail of six months in the Office of PresidentialPersonnel advising on individuals to fill positions on Boards and Commissions throughout thegovernment.
Transamerica Interway
I served as Vice President Government Affairs and Head of the Washington, D.C. Office for thesubsidiary of Transamerica Corporation that owned the largest fleet of ocean going containersand piggyback trailers in the world. I represented the Company before Executive Departments,the Congress and the Courts on legal and regulatory issues.
Arnall, Golden & Gregory
I was a Partner in the Washington, D.C. office of this Atlanta law firm. Our office specialized intransportation and safety matters before Congress, the Regulatory Agencies and ExecutiveDepartments. During that time I also taught regulatory management focused on surfacetransportation at the graduate business school of the University of Wisconsin and later taught apipeline seminar in a similar graduate program at Northwestern University. I published articlesin the Harvard Business Review and a number of transportation periodicals, and I testified manytimes before the Congress, the National Transportation Safety Board and regulatorycommissions on various transportation and safety issues.
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Office of Pipeline Safety, U.S. Department of Transportation
I ran the Office of Pipeline Safety from 1995 to 2000, where I had responsibility for the safe andenvironmentally sound operation of all pipelines in this country. In 1998 I received the SeniorExecutive Service Presidential Rank Award for my design and implementation of the FederalPipeline Safety Program. Under my leadership, the Office of Pipeline Safety changed the wayregulatory and enforcement resources were allocated to pipeline risks and devised moreeffective regulatory and enforcement strategies to address the highest risks. I created the firstPipeline Risk Management Demonstration projects and spearheaded the development ofPipeline Integrity Management. I also convened a Damage Prevention Quality Action Team thatdesigned the "Dig Safely" public education campaign for protecting all buried utilities.
Common Ground Alliance
The leading cause of pipeline accidents is excavation and construction damage. When I joinedthe Office of Pipeline Safety almost no resources were being devoted to this problem, and stateand local efforts were largely ineffective. I organized the Common Ground study in response toa request from Congress to identify "best practices" to protect all buried utilities and preventdamage to these important lifelines. I organized 160 working volunteers representing utilities,regulators, one-call centers, and the excavation community to do the study. The studyidentified 132 "best practices" and highlighted the need for improved communications andshared responsibility to prevent property damage and injury to those who live and work aroundburied utilities.
After I left the Office of Pipeline Safety, I spent one year founding and establishing the CommonGround Alliance whose purpose is to extend the work of the Common Ground study andprevent damage to all buried utilities including gas , electric, telecommunications, and waterand sewer lines. Today, the Common Ground Alliance has a 16 member Board of Directors, 7working committees and operates on a budget of contributions from utilities, excavationcompanies and the government. It works to improve safety codes, adopt new safety "bestpractices", promote new technologies, collect excavation damage data and advance publiceducation through the "Dig Safely" advertising message. Most recently, the Common GroundAlliance was the moving force behind the Federal Communications Commission mandating thenationwide 811 call before you dig telephone number. In 2014, I returned to address theCommon Ground Alliance's Annual meeting and was honored by being inducted into theCommon Ground Alliance Hall of Fame.
Consulting Work
My pipeline consulting clients include: BP, Southwest Gas, Equitable Resources, Ferrellgas,Elizabethtown Gas, Atlanta Gas Light and VirginiaNatural Gas.
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RICHARD E. SANDERS – CURRICULUM VITAE
Personal Information
Sanders, Richard E.
Operating Manager, RES Services LLC
5601 Castleridge Drive, Mustang, OK 73064
(405) 245-0061
Email: [email protected]
Education and Training
Mississippi State University -attended Industrial Engineering 1972 - 1973
Belhaven College - attended Industrial Engineering 1968 - 1969
Mississippi Delta Community College General Construction Technology 1964 - 1966
Professional Engineer Corrosion Engineering (#963) 1977 - 1978
Work Experience
U.S. DOT/PHMSA/PHP-70 Director 2005 – 2011
U.S. DOT/TSI/Pipeline Safety Division Manager 1984 – 2005
U.S. DOT/TSI/Pipeline Safety Division Pipeline Safety Specialist 1980 – 1984
Mississippi Public Service Commission Chief of Pipeline Safety 1976 – 1980
Mississippi Valley Gas Company Engineering HQ and District, Technical Assistant,
Construction, Survey Crew, Service department
and Systems dispatching 1966 – 1976
Strengths
Honest, effective and precise communication style and managerial techniques that establish and maintaintrust and create reliable, enduring partnerships
Ability to bring key players together with a shared goal; interaction and performance consistently markedby a balance of valuing all members of a process and meeting goals
Enhances productivity and effectiveness through interpersonal and relational skills to create a win-winenvironment
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Achievements
Extensive research efforts and regulatory experience were integral to the development of critical minimalperformance-based requirements for testing and evaluation criteria to determine suitability forunderground service in transmission, distribution and/or gathering systems (increase in design factor forPE piping systems, tracking and traceability, rapid crack propagation validation)
Collaboration and proactive efforts established Federal and State partnerships through formal trainingneeds job and task analyses of Federal and State pipeline inspectors; through workshops and job analysesresults, applied information to evaluate, improve and expand PHMSA training program
Established and facilitated the PHMSA OQ Inspection Team, comprised of PHMSA HQ and field personnel,State representatives and industry to establish critical milestones in developing OQ protocols, FAQs,guidance material, Nationwide inspections, development of a national database, public meetings andregional OQ training
List of Clients
AGA (American Gas Association) Trade Association, 400 North Capital Street NW Washington, DC 20001
Participate in PMC (Plastic Materials Committee) to monitor events for customers
Provide feedback on current issues and events
AGL - McKenna Long & Aldridge LLP, 303 Peachtree Street, Suite 5300, Atlanta, GA 30308
Provide consultant assistance in cases dealing with pipeline accidents and code compliance issues
APGA (American Public Gas Association) Trade Association, 201 Massachusetts Ave, NE Suite C-4, Washington
DC 20002
Participate in meetings as a guest speaker on current events such as TIMP, DIMP and operatorqualification code compliance issues
API – API, 1220 L Street, NW, Washington, DC 20005-4070 API 15S Spoolable Composites Materials
Consult for several vendors and provide current information on the development of standards, morespecifically API 15S new ANSI STANDARD
Arkema Inc., 900 First Avenue, King of Prussia, PA 19406
Provide consulting services in new pipe and appurtenances that company develops
Monitor project with operators who are using Arkema materials
Monitor and advise on special permits and R&D projects
Attend association meetings to advise Arkema on events and happenings that will affect their products
Work to get standards into regulation on behalf of Arkema
Monitor and advise on construction, operating and maintenance projects
ASME PCC2 – CRUG - Stress Engineering, 13800 Westfair East Dr., Houston, TX 77041-1101
Provide consulting services
Review test data on composite repair systems and report back to customer on findings andrecommendations
Provide code guidance and communication during meetings and conferences on code requirements
ASTM F-17, ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA, 19428-2959
Participate in the development of standards
Serve as Secretary of F17.10 Committee
Provide feedback current event information to customers on the development of standards and coderelated information
ATMOS - Balch & Bingham LLP, 188 East Capitol St., Suite 1400, Jackson, MS, 39201-2133
Provide consultant assistance in cases dealing with pipeline accidents and code compliance issues
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Borflex Pipe, Todd Volker, [email protected], (913) 544-2395
Provide pipe guidance on code compliance issues and requirements associated with the development ofspoolable composite pipe and appurtenances
Monitor and report developments at API 15S meetings regarding standards development
Monitor and report developments at ASTM F-17 meetings that may affect Borflex’s development ofmaterials and/or business
Center Point Energy, Legal Department, 800 LaSalle Avenue, Minneapolis, MN 55402
Provide code and regulations consulting for rate case dealing with gas transmission pipeline integritymanagement (TIMP) & gas distribution pipeline integrity management (DIMP) issues.
Dura-Line PolyPipe, Gainesville, TX
Provide regulatory guidance
Assist in developing new bimodal materials
Meet with customers on an as-needed basis
Monitor and advise on construction, operating and maintenance projects
Worked on new product development
Flexpipe, 3501 54th Ave SE, Calgary Alberta T2c0A9, Canada
Provide regulatory guidance
Assist with testing and special permits
Meet with operators, and regulators on behalf of Flexpipe
Represent Flexpipe at industry ANSI standard meetings such as API 15S
Monitor actions of trade associations (AGA, AGPA, SGA, MEA, APGA, NAPSR, and NARUC) and reportactions that might affect client interest
Work with Flexpipe’s customers on new project that need “Special Permits”
FlexSteel, 2103 City West Blvd, Suite 1450, Houston, TX
Provide regulatory guidance
Assist with testing and special permits
Meet with operators, and regulators on behalf of FlexSteel
Represent FlexSteel at industry ANSI standard meetings such as API 15S, ASTM F-17, etc. Monitor actionof trade associations (AGA, AGPA, SGA, MEA, APGA, NAPSR, and NARUC) and report actions that mightaffect client interest
Work with FlexSteel’ s customers on new project that need “Special Permits”
Gibbs & Bruns, 1100 Louisiana, Suite 5300, Houston, TX 77002
Provide review of pipeline section and discuss jurisdiction of pipeline segments
Review class location and comment on accuracy of data
Make suggestions on pipeline and areas to follow up on if project materializes
GTI (Gas Technology Institute) GTI Headquarters, 1700 S Mount Prospect Road, Des Plaines, IL 60018
Provide consulting services in TIMP, DIMP, OQ and code compliance requirements
Assist in development of cutting edge solution for operators of gas and liquid pipeline systems.
Hinckley, Allen & Snyder LLP, David Wollin, 50 Kennedy Plaza, Suite 1500, Providence, RI 02903-2319
Provide technical review of codes, standards and accident information in court case
Southern Union/New England Gas Co in Souza v Southern Union Co / New England Gas Co inMassachusetts Superior Court, C.A. 10-3538E (incident occurred February 19, 2009 in Somerset, MA)
Jana Laboratories, Inc., 280b Industrial Parkway S Aurora Ontario LTG 3T9 Canada
Consult on new technology for analyzing time to fail – Life cycle of materials, Review failure data and RootCause findings, provide guidance on regulatory and code compliance requirements, meet with and discussservices that JANA provides for Gas Industry.
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MICROBAC LABORTORIES INC, Hauser Division 4750 Nautilus Ct., South Boulder, CO 80301
Consult on new technology for analyzing time to fail – life cycle of materials
Review failure data and root cause findings
Provide guidance on regulatory and code
NAPSR - The National Association of Pipeline Safety Representatives
Provide current event training and speaking engagements during NAPSR meetings and training in States
Provide technical information to member
Polystrand, 8375 Highfield Parkway, Denver, CO 80112 (Edward Pilpel, President)
Provide technical input to regulations associated with spoolable composite pipe and appurtenances
Advise technical staff on code and standard expectations
Provide technical guidance on Parts 192 and 195 DOT Federal codes
Provide technical input on existing and proposed standards that affect spoolable composite pipe andappurtenances
Provide presentation history and current events information on pipeline issues
SGA (Southern Gas Association) 3030 LBJ Freeway, Suite 1300, Dallas, TX 75234
Participate in conferences and speaking engagements, training, video conferences, etc.
Monitor events and provide information to customers on happenings and current events
Smart Pipe Company, Inc. 1426 Vender Wilt Land, Katy, TX 77449
Provide regulatory guidance
Assist with testing and special permits
Meet with operators, and regulators on behalf of Smart Pipe
Represent Smart Pipe at industry ANSI standard meetings such as API 15S, ASTM F-17, etc Monitor actionof trade associations (AGA, AGPA, SGA, MEA, APGA, NAPSR, and NARUC) and report actions that mightaffect client interest
Monitor construction and special project permits and offer findings as needed to promote soundengineering practices and procedures
TEJ – 1521 Rolling Hills Drive, Crystal Lake, IL 60014
Provide consulting guidance on Code and regulations as well as contact on projects dealing with TIMP,DIMP, and OQ
Work together on R&D projects to update and develop improved technology for gas operators.
THERACOM – 100 West Long Rd Suite 220, Bloomfield Hills MI, 48304
Start-up company developing new piping systems for higher pressure and no cathodic protection needed
Provide consulting assistance in code compliance and standards
Advise processes to obtain special permits and path forward
USDOT/PHMSA/PHP-70, 3700 S. MacArthur Blvd. Suite B, Oklahoma City, OK 73179
Assist as associate instructor in training Federal and State pipeline inspectors
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Legal Clients – Court Case Listings
1. Law firm: King & Spalding LLP1180 Peachtree StreetAtlanta, GA 30309Contact: (404) 572- 4600
Amy Jones, King & Spalding 404/572-3598E-mail: [email protected]: Eastside Pipeline LitigationWork: Technical Consultant
2. Law firm: McKenna Long & Aldridge LLP303 Peachtree Street | Suite 5300 Atlanta, Ga 30308Contact: (404)527-4668James B. Manley Jr & Jill C. KuhnE-mail: [email protected] | [email protected]: Warren v. AGLCWork: Expert Witness
3. Law firm: Thompson Hine LLP3560 Lenox Road, Suite 1600Atlanta, Georgia 30326Office: 404-407-3640Contact: Russell J. Rogers | PartnerE-mail: [email protected]: Shanda Gould and Kevin Westbrook vs. Atlanta Gas Light Company; State Court of Fulton County:Civil Action File Number 2015CV259983Work: Expert Witness
4. Law firm: Lightfoot Franklin & White, LLCThe Clark Building400 20th Street NorthBirmingham, AL 35203-3200Contact: Michael L. BellDirect Dial: 205.581.0721E-mail: [email protected]: ALABAMA GAS Corporation | explosion at Marks Village on 12.17.13Work: Technical Consultant
5. Law firm: Armstrong Teasdale LLP2345 Grand Blvd., Suite 1500Kansas City, MO. 64108Phone: 816.221.3420Contact: Karrie J. ClinkinbeardE-mail: [email protected]: Abbott v. Missouri Gas Energy | Abbott Trial [IWOV-idocs.FID1761542]Work: Expert Witness
6. Law firm: AZA (Ahmad, Zavitsanos, Anaipakos, Alavi, Mensing)1221 McKinney Suite 2500, Houston, Texas 77010, Phone: 713-600-4958Contact: Shawn BatesE-mail: [email protected]
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Case: Enterprise Products Operating LLC f/k/a Enterprise Products Operating L.P. and Enterprise TEProducts Pipeline Company LLC f/k/a TE Products Pipelines Company LLC vs. Troy Construction, LLC andWood Group Mustang, Inc., f/k/a Mustang Engineering, LPWork: Expert Witness
7. Law firm: Balch & Bingham LLP, 188 East Capitol Street Suite 1400 • Jackson, MS 39201-2133t: (601) 965-8175 f: (888) 506 8673Contact: William L. Smith, PartnerE-mail: [email protected]
Case: CAUSE NO. 251-10-1082-CIV
JAMES T, MOSER, III AND NATALIE MOSER, Plaintiffs vs..
ATMOS ENERGY CORPORATION, HEMPHILL CONSTRUCTION COMPANY, INC., ET AL.
Work: Technical Consultant
8. Law firm: Plauché Maselli Parkerson, LLPPhone: 504.582.1142 | Direct: 504.586.5227701 Poydras Street, Suite 3800, New Orleans, La 70139-7915 USwww.pmpllp.comContact: BRUCE PARKERSONE-mail: [email protected]
Case: Dwayne Luttrell and Ida Neal vs. Duke Energy (Newport KY matter)Work: Technical Consultant
9. Law firm: : Plauché Maselli Parkerson, LLPPhone: 504.582.1142 | Direct: 504.586.5227701 Poydras Street, Suite 3800, New Orleans, La 70139-7915 USwww.pmpllp.comContact: BRUCE PARKERSONE-mail: [email protected]
Case: ATMOS ENERGY CORPORATION Waxahachie, Texas CASE NO. 92375Work: Technical Consultant
10. Law firm: Cathcart & Dooley, 2807 Classen Blvd., Oklahoma City, OK 73106Phone: 405-524-1110
Contact: Cary DooleyE-mail: [email protected]
Case: Oklahoma Natural Gas 8”Plastic failureWork: Technical Consultant
11. Law firm: Winthrop & Weinstine, P.ACapella Tower | Suite 3500 | 225 South Sixth Street | Minneapolis, MN 55402-4629Phone: (612) 604-6511United States of AmericaContact: Swanson EricE-mail: [email protected]
Case: Rate Case - CenterPoint EnergyWork: Technical Consultant
12. Law firm: SCHLEE, HUBER, McMULLEN & KRAUSE, P.C.4050 Pennsylvania, Suite 300, PO Box 32430, Kansas City, MO 64171Direct: 816-360-2590
P a g e | 11
Contact: David R. Schlee & Kathryn A. RegierE-mail: [email protected]
Case: Missouri Gas Energy v. JJ’s restaurantWork: Technical Consultant
13. Law firm: Hinckley, Allen & Snyder LLP50 Kennedy Plaza, Suite 1500, Providence, RI 02903-2319
28 State Street, Boston, MA 02109-1775
Phone: 401.457.5344
Contact: Mark D. Meredith I PartnerE-mail: [email protected]
Case: Southern Union/New England Gas Company in Souza v Southern Union Co./New England GasCompany in Massachusetts Superior Court, C.A. 10-3538E.Work: Technical Consultant
14. Law firm: Devin C. Reid, Liskow & Lewis, Suite 5000, One Shell Square701 Poydras Street, New Orleans, Louisiana 70139
Direct: (504) 556-4151
Contact: Devin C. ReidE-mail: [email protected]
Case: Chevron Midstream Pipelines, LLC, et al v. Settoon Towing, LLC, et alWork: Expert Witness
15. Law firm: NY Dept of Public Service Pipeline Safety3 Empire State Plaza, Albany, NY 12223Phone: (315) 428-5154www.dps.ny.govContact: Kevin Speicher Chief, Safety SectionE-mail: [email protected]
Case: ConEd East Harlem Accident 8” main & 2” service teeWork: Technical Consultant
16. Law firm: Southwest Gas CompanyPO Box 98510 | LVA-120 | Las Vegas, NV 89193.8510
Phone: 702.876.7182
[email protected] | www.swgas.com | www.swgasliving.com
Contact: Craig R. Roecks | Assistant General CounselE-mail: [email protected]
Case: Feb 9, 2014 incident in Gilbert AZWork: Technical Consultant
17. Law firm: Rendigs, Fry, Kiely & Dennis, LLP600 Vine Street, Suite 2650
Cincinnati Ohio 45202
Direct: 513.381.9327
www.rendigs.com
Contact: James J. Englert, Esq.E-mail: [email protected]
Case: Rising Sun, SYCAMORE GAS COMPANY58C01-1512-CT-0004
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Work: Expert Witness
18. Law firm: McGuireWoods LLPGateway Plaza, 800 East Canal Street, Richmond, VA 23219-3916T: +1 804.775.1039Contact: Perry W. Miles IVE-mail: [email protected]
Case: VNG CODE CASEWork: Expert Witness
19. Law firm: McGuireWoods LLP, JPMorgan Chase Tower600 Travis Street, Suite 7500, Houston, TX 77002-2906Phone: +1 832.255.6325Contact: Thomas M. FarrellE-mail: [email protected]
Case: Cause No. 2015-39021; Occidental Energy Marketing, Inc. and OXY Ingleside LPG Pipeline, LLC v.NuStar Logistics, LP; in the 11th Judicial District Court of Harris County, Texas.Work: Technical Consultant
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EXECUTIVE SUMMARY
Virginia Natural Gas’s Southside Connector Distribution Project is designed and will
be constructed to meet or exceed all applicable pipeline safety standards. It will be
operated and maintained to provide the natural gas requirements of the City of
Norfolk safely and reliably. To provide the safest possible route, it will be built in
existing utility right-of-way and use easements on city owned property on land and
on existing easements across the Elizabeth River.
Colonna’s safety concerns are based on a report prepared by R. D. Deaver entitled
“Potential Impacts of the Southside Connector”. Colonna’s safety concerns have
also been reviewed and amplified by another consultant, Richard Kuprewicz.
Kuprewicz also offered a list of “Safety Related Land Use Questions”. Deaver’s
paper and Kuprewicz’s review hinge on certain key assumptions. First, and
foremost, is the mistaken notion that the Federal pipeline safety regulations, 49
CFR Part 192, are formulated as “minimums” and are insufficiently protective of
people and property. Second is an unfounded and unsupported belief that the
Southside Connector is a high-pressure transmission line that is so dangerous that
it can only be effectively regulated if it is subjected to the licensing standards of the
Federal Energy Regulatory Commission (FERC) and measured by “best practices”
for siting such pipelines suggested by FEMA and the Pipeline and Hazardous
Materials Safety Administration (PHMSA) of the U.S. Department of
Transportation. The Kuprewicz Land Use Questions are equally misplaced. There
are local and Federal laws and regulations that answer all of his questions.
The Southside Connector Distribution Project involves constructing the last eight
miles of a two-hundred-mile pipeline between Quantico, VA and Norfolk, VA. We
have examined three years of operating data which conclusively demonstrates that
the pipeline has been and will be operated at pressures which guarantee the
highest possible margin of safety while effectively supplying the energy needs of
Norfolk’s residents and businesses. This data shows that Colonna’s safety concerns
and dire predictions are totally unfounded. VNG has committed to the City of
Norfolk to adhere to this safe operating plan for the Southside Connector.
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Measured against the Federal pipeline safety regulations, which are the standards
that apply to the design, construction, maintenance and operation of an intrastate
natural gas transmission line, the Southside Connector meets or exceeds the
regulatory requirements. The pipeline will be thoroughly inspected by the Pipeline
Safety Division of the Virginia State Corporation Commission and tested for
possible flaws or imperfections before it is placed in operation. The pipeline will be
maintained and operated under an Integrity Management Plan approved by the
regulators. Finally, the pipeline will be monitored and controlled 24/7, including
the ability to remotely operate shut-off valves. With all these safeguards in place,
the City of Norfolk should feel safe and secure as the final phase of the Southside
Connector Distribution Project is completed.
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SAFETY ANALYSIS
The Federal pipeline safety regulations are a compendium of best practices and
safety standards tailored to protect people and the environment from potential
risks posed by pipelines. Colonna’s persistent use of the term minimum federal
safety requirements as a pejorative exposes its misunderstanding of how Federal
pipeline safety regulations work. Experts who have the requisite education and
experience working with safety regulatory laws are familiar with using statutory
minimum standards to provide enhanced public protections. A careful reading of
the Federal pipeline safety regulations by Colonna’s consultants would have
answered all of the questions and concerns that they are raising for the first time
as construction is scheduled to begin.
The most serious problem with Colonna’s concerns is the mistaken view that VNG’s
unquestioned compliance with Federal pipeline safety regulations that govern the
safe design, construction, maintenance and operation of the Nation’s pipelines is
not dispositive of Colonna’s safety concerns. They refuse to acknowledge how
these regulations provide the precise protections that they claim can only come
from prohibiting construction in the planned right-of-way. Colonna’s safety
concerns do not address actual deficiencies in the Southside Connector that would
prompt genuine safety issues. Colonna’s expresses fear of a catastrophic failure
which they attribute to what they term unpreventable human errors or “other
causes beyond the control of the utility company in certain pipeline locations”.
Colonna’s also underestimates the value of regulatory compliance by repeatedly,
falsely stating that the Southside Connector suffers from “mere compliance with
minimum federal requirements”
Colonna’s dismissal of Federal pipeline safety standards as insufficient to protect
the public or an inferior substitute for “common sense” pipeline siting is a self-
serving argument that is not supported by the facts. Everyone would agree that you
cannot regulate away all risks but you can manage these risks effectively by
complying with and exceeding Federal pipeline safety regulations. Pipelines are not
P a g e | 17
banned from high consequence areas (HCA). 1 Instead, the regulations call for
pipeline operators like VNG to have an Integrity Management plan to assess and
address pipeline risks in HCAs. Pipelines are not banned from navigable waterways.
The Navy looks to Federal pipeline safety regulations and the Army Corps of
Engineers permitting process for protection.
Finally, Colonna’s devotes considerable attention to a Hazard Mitigation Planning
study jointly developed by FEMA and PHMSA. This is an excellent primer on pipeline
risks. It was written to assist cities trying to understand the best way to work with
high pressure transmission lines regulated by FERC. Again, before citing this study
or referring to horrific accidents on pipelines that bear no relation to the Southside
Connector, Colonna’s needs to point to the design, construction, operating or
maintenance characteristics that support comparing the Southside Connector to
1 HCA definition is: High consequence area means an area established by one of the methods described in paragraphs (1) or (2) as
follows:
(1) An area defined as-
(i) A Class 3 location under §192.5; or
(ii) A Class 4 location under §192.5; or(iii) Any area in a Class 1 or Class 2 location where the potential impact radius is greater
than 660 feet (200 meters), and the area within a potential impact circle contains 20 or more buildings intended for human
occupancy; or
(iv) Any area in a Class 1 or Class 2 location where the potential impact circle contains an identified site.
(2) The area within a potential impact circle containing-
(i) 20 or more buildings intended for human occupancy, unless the exception in paragraph (4) applies; or
(ii) An identified site.
(3) Where a potential impact circle is calculated under either method (1) or (2) to establish a high consequence area, the length of
the high consequence area extends axially along the length of the pipeline from the outermost edge of the first potential impact
circle that contains either an identified site or 20 or more buildings intended for human occupancy to the outermost edge of the
last contiguous potential impact circle that contains either an identified site or 20 or more buildings intended for human
occupancy. (See Figure E.I.A. in Appendix E.)
(4) If in identifying a high consequence area under paragraph (1)(iii) of this definition or paragraph (2)(i) of this definition, the
radius of the potential impact circle is greater than 660 feet (200 meters), the operator may identify a high consequence area
based on a prorated number of buildings intended for human occupancy with a distance of 660 feet (200 meters) from the
centerline of the pipeline until December 17, 2006. If an operator chooses this approach, the operator must prorate the number of
buildings intended for human occupancy based on the ratio of an area with a radius of 660 feet (200 meters) to the area of the
potential impact circle (i.e., the prorated number of buildings intended for human occupancy is equal to 20 x (660 feet) [or 200
meters]/potential impact radius in feet [or meters].
P a g e | 18
these other pipelines. Colonna’s persists in viewing the Southside Connector as a
high-pressure transmission line of the type that would serve as an interstate facility
delivering large quantities of natural gas at a transfer point at the edge of the city
for subsequent distribution to homes and businesses. It has offered diagrams that
depict large scale fire and blast zones that extend long distances from the pipeline
route. It has distributed videos of highly disturbing scenes following pipeline
ruptures. The FEMA and PHMSA study and the diagrams and videos have no
application to the Southside Connector which will be a component of VNG’s
distribution system.
Colonna’s call for additional study and delay is supported by a list of supposed
shortcomings in the Federal pipeline safety regulations. One complaint is that the
regulations do not control the location of pipelines and do not require operators to
follow best safety practices. In fact, the regulations use a combination of well-
defined class locations, material and construction standards that tell an operator
how it must build in a particular location which effectively establishes where the
operator can build. As far as best practices are concerned, the regulations are a
comprehensive set of standards for design, construction, maintenance and
operation of natural gas pipelines. Their origin was various codes developed by
consensus standards organizations like the National Association of Corrosion
Engineers, the American Society of Testing and Materials and many others. These
codes are recognized throughout this country and the world as the product of
subject matter experts from industry, academia and regulatory bodies. The
regulations have been revised and improved over 120 times to incorporate evolving
changes in technology and regulatory innovations. The regulations are not
minimums from a safety perspective. They are only termed minimums because
operators are obligated to meet or exceed them. Everyone, including the shipyard,
agrees that the Southside Connector complies with the regulations. We will explain
how the pipeline not only meets but also exceeds regulatory requirements in many
important areas.
A good starting point for a valid safety assessment of the Southside Connector is
the fact that it exceeds federal safety standards in several important areas including
P a g e | 19
the pipeline’s wall thickness and burial depth. 2 Importantly, the pipeline is
designed to be built in areas that are heavily populated and contain multi-story
2 Burial Depth requirement found in CFR 49 Part 192 are found in Part 192.327 Cover:
(a) Except as provided in paragraphs (c), (e), (f), and (g) of this section, each buried transmission line must be installed
with a minimum cover as follows:
Location Normal soil Consolidated rock
Inches (Millimeters)
Class 1 locations 30 (762) 18 (457)
Class 2, 3, and 4 locations 36 (914) 24 (610)
Drainage ditches of public roads and railroad crossings 36 (914) 24 (610)
(b) Except as provided in paragraphs (c) and (d) of this section, each buried main must be installed with at least 24
inches (610 millimeters) of cover.
(c) Where an underground structure prevents the installation of a transmission line or main with the minimum cover, the
transmission line or main may be installed with less cover if it is provided with additional protection to withstand
anticipated external loads.
(d) A main may be installed with less than 24 inches (610 millimeters) of cover if the law of the State or municipality:
(1) Establishes a minimum cover of less than 24 inches (610 millimeters);
(2) Requires that mains be installed in a common trench with other utility lines; and,
(3) Provides adequately for prevention of damage to the pipe by external forces.
(e) Except as provided in paragraph (c) of this section, all pipe installed in a navigable river, stream, or harbor must be
installed with a minimum cover of 48 inches (1,219 millimeters) in soil or 24 inches (610 millimeters) in consolidated rock
between the top of the pipe and the underwater natural bottom (as determined by recognized and generally accepted
practices).
(f) All pipe installed offshore, except in the Gulf of Mexico and its inlets, under water not more than 200 feet (60 meters)
deep, as measured from the mean low tide, must be installed as follows:
(1) Except as provided in paragraph (c) of this section, pipe under water less than 12 feet (3.66 meters) deep, must be
installed with a minimum cover of 36 inches (914 millimeters) in soil or 18 inches (457 millimeters) in consolidated rock
between the top of the pipe and the natural bottom.
(2) Pipe under water at least 12 feet (3.66 meters) deep must be installed so that the top of the pipe is below the natural
bottom, unless the pipe is supported by stanchions, held in place by anchors or heavy concrete coating, or protected by
an equivalent means.
(g) All pipelines installed under water in the Gulf of Mexico and its inlets, as defined in §192.3, must be installed in
accordance with §192.612(b)(3).
P a g e | 20
buildings; so-called Class 4 locations. Thus, if additional development takes place
along the pipeline route, protections are already built in.
Rather than evaluate whether the Southside Connector complies with applicable
safety standards, Colonna’s offers a list of potential pipeline failures but makes no
effort to examine how the Southside Connector is designed to minimize or
eliminate the risk of these types of failures. For example, to address the risk of
manufacturing defects or welding flaws, before the pipeline is placed in service,
VNG plans to pressure test the pipeline to 90% SMYS. A baseline internal inspection
by “smart pigs” will be run to evaluate any problems that may pose a safety risk to
the pipeline. In other words, both the strength of the pipe and the construction of
the pipeline will be safety checked before it ever operates. In addition, the pipeline
is designed to be periodically tested with “smart pigs” to detect any defects like
dents, gouges, cracks or wall thinning after the line is placed in operation. Also, on
Colonna’s list of potential failure modes is internal or external corrosion. Of course,
VNG’s design specifications include external coating and a cathodic protection
system to prevent and monitor external corrosion. Any internal corrosion will be
spotted by the aforementioned internal inspections. In addition, zinc ribbon
cathodic protection has been designed into the pipeline to mitigate induced AC
current and stray DC current which might interfere with cathodic protection levels
already required by regulation. Likewise, there is no recognition of VNG’s damage
prevention program or its plan to spend extra dollars to use existing right-of-way
to minimize the potential for excavation damage. Colonna’s approach of simply
listing failure modes without any examination of VNG’s plans and ongoing actions
to address these potential risks was not helpful.
P a g e | 21
SAFETY ASSESSMENT
First let’s clarify what this pipeline really is. The “Transmission Line” definition
found in Part 192 - Transportation of Natural and Other Gas by Pipeline Minimum
Federal Safety Standards states:
Transmission Line means a pipeline, other than a gathering line, that:
(1) Transports gas from a gathering line or storage facility to a [gas] distribution center,
storage facility, or large volume customer that is not down-stream from a [gas]
distribution center; (2) operates at a hoop stress of 20 percent or more of SMYS; or (3)
transports gas within a storage field.
The Southside Connector is a pipeline covered under the Federal and State
regulations because it is an Intrastate Transmission Line that operates at a hoop
stress of 20 percent or more of SMYS (specified minimum yield strength).
Colonna’s likes to describe the pipeline as a high-pressure transmission line. As
designed, the line will be constructed of API 5L X65 steel .500 wall thickness and
operated with an MOP (Maximum Operating Pressure) from 500 to 1000 psig. This
combination of material strength and operating pressure produces a stress level on
the pipe of 18% to 37% SMYS (specified minimum yield strength) which is at times,
less than the 20% SMYS definition for transmission and is considered to be
distribution pressure. This means that even though the pipeline meets the technical
definition of a transmission line, it will be operated way below allowable
transmission pressure. Using stronger steel and lower operating pressure
mathematically aids in eliminating the chance of a rupture. Industry groups and
academics have studied the stress levels on a pipeline facility, and over the years,
has found any pressures below 30% SMYS will leak before rupture. When a pipeline
is operated at low pressures that will produce a leak before a rupture in the event
of a material failure, the potential for a rupture and explosion is eliminated, and
the pressure drop occasioned by the leak can be detected and the leak can be
repaired. A table to follow will show the stress levels in more detail and will show
the overdesign safety levels adopted by VNG.
To confirm that the design and proposed operating plan for the pipeline are
realistic and attainable, we examined three years of operating history of the other
90 % of the pipeline that is already in service. In particular, we looked at the inlet
P a g e | 22
pressure readings for the Salter Street Station which is the northern connection of
the Southside Connector. The results should provide real comfort to the City of
Norfolk. 97% of the operating hours were below 813 PSIG which is the 30% SMYS
level. 58% of the operating hours were below 541 PSIG. Which is the 20% SMYS
level. At no time did the pipeline exceed the maximum allowable operating
pressure of 1250 PSIG. These numbers show that the safe design and operation of
this pipeline is assured.
This line is monitored by the State of Virginia Pipeline Safety Division through an
agreement with the Federal Government. DOT has an agreement with the State of
Virginia to inspect and enforce the regulations on intrastate facilities. This
Federal/State partnership program has been in existence since 1968 based on the
Congressional mandate, requiring the U.S. Department of Transportation (DOT) to
develop a set of pipeline safety regulations (CFR 49 Part 192). There are 52 State
entities that have agreements with DOT to enforce the Federal regulations. FERC
does not regulate intrastate transmission pipelines.
Design of the pipeline facility is required to follow specific “parts,” “subparts,”
“sections” and “appendices” of the regulations dealing with all aspects of design,
construction, operation, corrosion, welding, maintenance, and emergency
response of pipe and appurtenances. For placement of a pipeline (intrastate
transmission line) a pipeline operator must design and comply with subparts “A,”
“B,” “C,” “D,” “E,” “G,” “I,” “J,” “L,” “M,” “N,” “O,” “P,” and Appendices “B,” “D,”
and “E.” The starting point is determining class location of the pipeline that is to
be constructed. This will drive all other areas of consideration such as: material
selection (pipe), components (valves, flanges, etc.), welding, maximum allowable
operating pressure (MAOP), maximum operating pressure (MOP), corrosion,
testing, regulator & relief, metering, employee qualification, integrity
management, smart-pigging, etc.
The Southside Connector pipeline facility is in a Class 3 area; therefore, pipe and
appurtenances must comply with this specific class location. Because of the entire
facilities being in a Class 3 HCA, the requirements are applicable for the entire
length of the facilities. It should be noted that VNG design engineers and consulting
P a g e | 23
engineers chose to design and build a pipeline facility comparable to a Class 4
pipeline facility, making these facilities safer than Federal regulations would
require. This involved more cost and effort on VNG’s part but was designed to
promote pipeline safety for their customers and the general public. Building in Class
4 protections also accommodates future development along the pipeline without
having to make safety adjustments to the pipeline. This is all part of VNG’s plan to
fulfill its obligation as a public utility in the safest possible way.
Let’s talk more specifics about the Southside Connector. Pipe that will be used to
construct this pipeline will meet API Specification 5L, “Specification for Line Pipe,”
45th edition, effective July 1, 2013, (API Spec 5L), IBR approved for
§§192.55(e); 192.112(a), (b), (d), (e); 192.113; and Item I, Appendix B to Part 192.
The pipeline will be constructed below 50% SMYS which is comparable to a Class 4
pipeline. Designing the pipeline with the intention of always operating at less than
half of the MAOP (maximum allowable operating pressure) offers an exceptional
margin of safety. The pipeline will be constructed of API 5L X65 steel 24” pipe with
a wall thickness of .500. Applying the design formula from §192.105, the SMYS
levels that will be obtained are shown in the table below. What this really means is
that VNG has built in a very wide margin of safety by using stronger pipe and
operating it at highly reduced pressure shown in the bottom line of the chart. The
leak before failure potential is not reached until the pressure exceeds 812 PSIG at
30% SMYS. VNG has exceeded the Federal Regulations in several areas. Some of
these added safety areas are addressed in the following SMYS table.
Pipeline Pressures associated with design,MAOP, MOP, SMYS CFR 49 §§ 192.105
Specified Minimum Yield Strength(100% SMYS) P=2x65000x.500/24Barlow Formula
2708 PSIG 100%
1250 PSIG - MAOP 46%
1000 PSIG - high MOP 37%
812 PSIG – leak before failure 30%
542 PSIG 20%
500 PSIG – low MOP 18%
P a g e | 24
Pipeline efforts to exceed Federal Pipeline Regulations
Pipe Material: Higher strength steel pipe than required – API X65 steel pipe was
selected so %SMYS at MAOP is 46%. Code would have allowed API – X60 pipe to
be used making the %SMYS at 50%.
Valve Spacing: CFR 49 192.179 addresses valve requirements. The Southside
Connector pipeline is an 8.1-mile facility and it could have been built as a Class 3
pipeline in accordance with Federal regulations with valve spacing 4 miles apart
and with manually operated valves. As designed there will be shutoff valves at
Salter Street, Chesapeake Gate Station and DD Jones Property (Berkley Ave). Each
location on the pipeline is within 2½ miles of a remote-control valve (RCV). Spacing
for a Class 4 facility is: Each point on the pipeline in a Class 4 location must be
within 2½ miles (4 kilometers) of a valve. All shutoff valves will be remotely
operated and monitored 24/7/365. In other words, valve number, type and spacing
all exceed the regulatory requirements.
Cathodic Protection System: Sacrificial anodes (magnesium and/or zinc ribbon)
will be used along the pipeline to provide cathodic protection to the VNG pipeline
facilities to minimize interference problems (stray DC and induced AC interference)
from nearby facilities (ship yards [Colonna], railroad, telephone cable, power lines
and other facilities emitting DC current). Zinc ribbon will be installed along the side
of the pipeline to drain off, mitigate interference problems and protect coating.
This addresses the shipyard’s concerns about how the pipeline will be protected
from the high-powered electrical equipment used in ship construction.
Construction Inspection: VNG hired an independent third-party inspection agency
to monitor all construction activity. This is not required by Federal regulations. VNG
continues to use their employees to inspect along with the State Corporation
Commission Pipeline Safety Division inspectors, who have inspected the pipeline
more than 45 times.
All production welds will be nondestructively inspected using qualified personnel
to visually inspect and will be 100% x-rayed to ensure all critical anomalies are
found and repaired before placing the Southside Connector pipeline into service.
P a g e | 25
All pipe and materials were inspected and approved by a third-party metallurgical
engineering firm. All company employees, third-party inspectors and contractor
personal are operator qualified in accordance with the regulations in Part 192
Subpart “N.”
VNG will do an in-service in-line inspection (smart-pig) run at conclusion of
construction. Regulations would only require a run within a 10-year interval from
completion of the project.
Periodic Inspections / Maintenance: There will be annual regulator and relief valve
station inspections in accordance with CFR 49 §192.739 Pressure limiting and
regulating stations: Inspection and testing. There will be bi-weekly roadway
crossing inspections which exceeds regulations. There will be monthly aerial
patrols of rights-of-ways (ROWs) exceeding regulations. There will be quarterly
readings of cathodic protection (CP) test sites and monitoring and review of AC
mitigation systems which are over and above what regulations would require
(found in Subpart “I” and CFR 49 §192.465). Each pipeline that is under CP must be
tested at least once each calendar year, but with intervals not exceeding 15
months, to determine whether the CP meets the requirements (again more
frequent evaluation of cathodic protection system to promote safety).
Safety Oversight after Construction is Completed
The Deaver report states that there are no pipeline safety “police” to prevent
operators from shaving costs to reduce safety. He also believes that penalties for
non-compliance are minimal. In fact, PHMSA has a nationwide enforcement staff
overseeing interstate operators supported by State pipeline safety offices to
monitor intrastate operators. As noted before, the Southside Connector has been
inspected during construction and operation over 45 times. Indeed, Virginia has
signed an agreement with PHMSA that requires an inspection and enforcement
effort that assures that pipeline operators meet or exceed Federal safety standards.
The statutory penalties for violating pipeline safety requirements are set at up to
$200,000 per infraction and can run into millions of dollars for serious findings of
non-compliance.
P a g e | 26
The Deaver report faults the regulations for being vague and general in setting
standards for safety activities. He expresses a preference for regulations that
specify “how to perform” safety activities. Again, this demonstrates his limited
knowledge of the whys and wherefores of natural gas safety regulation. Regulators
always have a choice between using performance standards or prescriptive
requirements. Prescriptive requirements are chosen when there is only one
preferred method to accomplish a safety task. Performance standards are
appropriate for the infinite variety of natural gas facilities where one size does not
fit all. Differing climates, soil conditions and operating environments demand
tailored solutions, not cookie cutter approaches. The suggestion that allowing
operators to determine how best to comply with a performance standard is
somehow a free pass or poor regulatory policy is not true.
Finally, the Deaver report has a strong preference for local control rather than
Federal oversight. It fails to realize that PHMSA oversight delivers the best of both
worlds. The Federal regulatory program can access best practices from all sources.
The regulations are adopted and updated through a process that allows maximum
public participation and review by carefully selected pipeline safety advisory
committees. These are the regulations applied and enforced in the State of Virginia
by the State Corporation Commission’ s Pipeline Safety Division. The licensing
standards of FERC do not apply nor do the advisory recommended practices
developed jointly by the DOT and FEMA as required by the 1992 Pipeline Safety
Improvement Act. In addition, U.S. Environmental Protection Agency (EPA) risk
management regulations do not apply to the operation of this pipeline. The reason
that these other regulatory requirements do not govern the design, siting or
operation of the Southside Connector is obvious. There is already a comprehensive
set of safety regulations, designed specifically to protect people and the
environment from any and all risks posed by natural gas pipelines.
When the Deaver report and Kuprewicz’s review shifts focus from the regulations
to the pipeline itself, the big problem is the pipeline they condemn as an inherently
dangerous, high-pressure gas transmission pipeline does not match the Southside
Connector that VNG designed or plans to operate. Their assumptions about how
the pipeline will inevitably rupture at the maximum allowable operating pressure
P a g e | 27
due to human error or some other cause beyond the control of the operator has
no basis in the actual proposed design, construction, maintenance plan and
operation of the Southside Connector.
Colonna’s acknowledgement that the Southside Connector meets the
requirements of Federal pipeline safety regulations and insistence on confining
their safety concerns to a non-existent high-pressure transmission line makes their
safety concerns ring hollow. Nothing Colonna’s says detracts from our carefully
researched and well documented assessment of the safety profile of the Southside
Connector.
The balance of our assessment will concentrate on why we believe the Southside
Connector is designed to operate safely in Norfolk. We understand that the Navy
has no concerns about the safety of the pipeline. The Navy rightfully relies on
Federal pipeline safety regulations and the Army Corp of Engineers to protect their
interests. In addition, we will explain how the design and proposed operation of
the pipeline should not interfere with future development along the carefully
chosen right-of-way.
Virginia Natural Gas has been working with Colonna’s for approximately 2 years on
the alignment of the Southside Connector. The pipeline is designed to exceed
Federal safety requirements in many ways, and they have communicated that to
Colonna’s Shipyard.
We learned that VNG consultants conducted a route survey that examined five
alternative routes. The route finally selected was based on the safest route for both
construction and on-going maintenance and operation of the pipeline. Cost was
not the main driver. The route selected was priced approximately $8 million higher
than the next alternative.
Regarding the alignment of the Elizabeth River Crossing, VNG is collocating the
Southside Connector within two existing easements – a water pipeline and an 80
ft. City of Norfolk easement. The Southside Connector will not impose any
additional restrictions on future development.
P a g e | 28
VNG designed the Southside Connector pipeline under the Elizabeth River, and
Colonna’s Shipyard, at a depth that far exceeds Federal requirements. HDD
(Horizontal Directional Drilling) drilling the pipeline at these depths (70’ to 90’ plus
feet deep or more) will preserve the navigational channels and not limit the
region’s ability to dredge the channel to greater depths. Additionally, the HDD will
prevent any operational or surface impacts at Colonna’s Shipyard. The HDD will
begin at Harbor Park, continue underneath the shipyard, and resurface on the City
of Norfolk right-of-way.
Lastly, Colonna’s is misinformed regarding VNG’s plans to install shutoff valves
along the line. VNG will have one at each end and one approximately in the center.
In fact, the spacing of these valves not only exceeds Federal requirements but also
includes remote shutoff capability that is monitored 24/7/365.
One final note about Kuprewicz’s list of land use questions. They are either fully
addressed in existing laws and regulations or are related to the FEMA/PHMSA
guidelines for FERC regulated intrastate transmission lines that have no application
to the Southside connector. Three of his questions relate to selecting the
appropriate depth of cover for the pipeline. That subject is covered by Federal
pipeline safety regulations and the Southside Connector exceeds the requirements.
There is a question about terrorist threats but it is generally accepted that such
threats are limited to above ground facilities that are not an issue for this project.
Most of the questions raise damage prevention, construction or zoning issues. The
simple answer to these questions is that there is no reason to treat this project
differently from any other structure or utility. The federal pipeline safety
regulations and local laws address every one the questions he raises. The remaining
questions concern conditions in the existing right-of-way that might affect the
pipeline. These have been addressed in VNG’s plans and will continue to be
addressed in construction which will be overseen by the State Corporation
Commission’s Division of Pipeline Safety.
P a g e | 29
CONCLUSIONS
VNG has complied with all applicable regulations (CFR 49 Part 192) and
incorporated by reference industry standards (API, ASME, ASTM, GTI, MSS, NACE,
NFPA, ANSI, PRCI, and AGA). Pertinent industry standards can be found in CFR 49
Part 192.7. Construction of the pipeline should not interfere with any present or
future plans to develop property along the right of way because of the design,
operating and maintenance standards followed by VNG. The margin of safety built
into the design, construction, proposed operation and scheduled maintenance of
this pipeline provide maximum protection to the City of Norfolk. We are available
to address any additional questions or concerns you might have.
