HomeMy WebLinkAboutC_Public_Comment_78Date: January 8, 2020
Subject:
City of Renton Permit Hearing - Application of Puget Sound Energy for Conditional Use Permits for Four
Miles of 230 kV Transmission Lines: Application LUA18-000055,CUP-H,SME
Written Comments - Request to deny permit based on noncompliance - SAFETY
To: The Honorable Phil Olbrechts, Renton Hearing Examiner
From: Barbara Braun - 13609 SE 43rd Place, Bellevue WA 98006
Bellevue City Staff Report Claim
Refer to City Staff Report – Pipeline Safety pages 78-80, 93
➢ “PSE and Olympic have worked together in the corridor for 40 years and communicate regularly to coordinate
activities related to pole replacement and other maintenance work”. (Source: City Staff Report page 93,
Section1)
➢ “The risk assessment completed for the EIS indicates that there will be a very small increase in total risk during
construction.” (Source: City Staff Report page 93, Section1)
➢ “… the Project is not expected to increase the risks of accidental release due to seismic activities or other natural
forces, and that overall the operations risks would decrease.” (Source: City Staff Report page 93, Section 2)
➢ “Because existing local service providers are expected to be adequate to address increased demand for fire and
emergency response services for construction … impacts on emergency services would be minor”. (Source: EIS,
Pipeline Fire or Explosion 15.3.1.3 (P15-5-6,10))
A Different Conclusion
No assessment of pipeline safety during and after construction was completed for the City of Renton. No assessment
of emergency response was completed. Safety and resiliency risks far outweigh any reliability benefit of the Energize
Eastside proposed solution. PSE has not adequately considered lower risk alternatives. The proposed solution is not
safe or prudent for citizens and must be rejected.
Energize Eastside Is LUC and SEPA Non-Compliant
There are many reasons why Energize Eastside (EE) is unsafe and should be deemed LUC and SEPA Non-Compliant:
1. EE should be scoped as a high-risk project
2. The EE proposal does not follow industry design practices for the co-location of pipeline and transmission lines
3. The EE proposal has inadequate safety design
4. The EE proposal has an inadequate accident response plan
5. The EE evaluation of risk does not stand up to independent review
6. There is reasonable precedent for high safety concern
The following sections provide details on these 6 points:
1. EE should be scoped as a high-risk project:
PSE says that historically it has been the practice that it’s the pipeline company’s duty to ensure the pipeline is safe
after the PSE pole work is done. Energize Eastside is an extra high-voltage transmission line that would run next
to schools, churches, parks and through neighborhoods. New poles will require deeper and wider holes (up to 6 feet
wide and 25 feet deep). The energy capacity of the lines will be quadrupled. The 58-year-old pipelines, 16 inches
and 20 inches respectively, are buried between three and four feet deep and carry 4.5 billion gallons diesel, jet fuel,
and gasoline per year. Hundreds of children attend schools within unsafe distances of the transmission lines and
pipelines. (Source: Draft Environmental Impact Statement (DEIS) prepared for the East Side project).
This is a densely populated residential corridor. The EIS defines risk as the likelihood of an accident multiplied by the
magnitude of the consequences. Although the likelihood of a pipeline accident is low, the dire consequences are
practically beyond imagination. Therefore, the total risk is significant. It would be irresponsible for any permitting
agency to dismiss or ignore these issues.
2. The EE proposal does not follow industry design practices for the co-location of pipeline and transmission lines:
230 kV power lines are not commonly installed near homes and schools. It’s even less common to install poles
within feet of aging petroleum pipelines. By either of the following standards, the current Energize Eastside design
does not comply with current design standards:
2.1. California state codes require at least 1,500 feet of separation between hazardous pipelines and schools. CCR
Title 5, Section 14010(h) states: “the site shall not be located … within 1,500 feet of the easement of an above
ground or underground pipeline that can pose a safety hazard as determined by a risk analysis study, conducted
by a competent professional.” (Source: www.cde.ca.gov/ls/fa/sf/documents/v1prtocolsec1.doc)
2.2. The Bonneville Power Administration, the federal agency responsible for regional transmission in the Pacific
Northwest, recommends a 50-foot separation between power poles and pipelines. (Source:
https://www.bpa.gov/news/pubs/GeneralPublications/lusi-Living-and-working-safely-around-high-voltage-
power-lines.pdf).
3. The EE proposal has inadequate safety design:
Prior to permitting any solution, the City and PSE need to address all questions/concerns raised during the EIS
process since the project has many risks due to construction, corrosion, and earthquakes that could manifest into
unspeakable disaster. Current EE proposal inadequacies that must be addressed are:
3.1. Inadequate safe separation standards:
1. What is a safe separation between power poles, transmission lines, and high-pressure petroleum
pipelines? What contemporary best practice will be followed?
2. Are there any significant differences in electrical conductivity between the steel monopoles proposed
by PSE and a “BPA tower?”
3. Are there other differences between PSE and BPA transmission lines that would justify collocation
closer than BPA’s recommendation (50 feet)?
3.2. Inadequate construction safety design and mitigation:
PSE says that every safety precaution will be taken, but there will be many opportunities for mishaps along the
route. PSE contractors will dig foundation holes up to 6 feet wide and 25 feet deep. PSE claims that it is safe to
excavate these foundations very close to the pipelines. Even if direct impacts are avoided, excavation will induce
vibrations on the pipelines. Heavy equipment will be driven on top of the pipelines.
The latter is specifically addressed by the Chevron
Company in its safety brochure, which warns that
construction equipment should be 15,000 pounds
or less, and that the pipeline should be buried at
least 4 feet. The depth of the Olympic Pipeline
varies from 2.5 to 4 feet throughout the corridor.
Breach of the pipeline would be extraordinarily
destructive in such a densely residential area.
(Source:
http://www.chevronpipeline.com/pdf/Guidelines_f
or_Property_Development.pdf)
Chevron has guidelines for vehicle weight
and pipeline depth to avoid indirect damage.
1. What specific safety assurances can PSE provide the public regarding the construction of the
transmission line? How can digging vibration be minimized in close proximity to the pipelines?
2. Will construction vehicles drive over the pipelines, and what is the upper limit on their combined
weight?
3. In past years, PSE has evacuated nearby homes when excavation is done near the pipelines. What
are PSE’s specific plans for evacuation during construction, including duration as well as the number
of houses, businesses, schools, and churches that will be affected.
3.3. Inadequate accelerated corrosion risk mitigation:
A 2015 paper by DNV-GL entitled Criteria For Pipelines Co-existing with Electrical Powerlines prepared for the
Interstate Natural Gas Association of America, describes the risk factors for accelerated corrosion of pipelines due to
collocated power lines:
• Distance to power lines - A separation of less than 100 feet
is judged to be high risk. In parts of the Somerset
neighborhood, the separation will be as low as 60 feet.
This is alarming because the electric field strength
increases exponentially as the distance decreases.
• Amount of current - Current magnitude greater than 1000
amps is judged high risk. PSE says the transmission lines
will have a capacity of approximately 1500 amps, 50%
higher than DNV-GL cites in its risk table.
• Length of parallel collocation - The authors of the DNV-GL
paper evaluated risk for infrastructure collocated for
distances up to 5000 feet, which was considered high risk.
PSE’s lines will be collocated with the pipeline for at least
16 miles, greatly exceeding DNV-GL’s risk tables.
• Soil resistivity - No measurement has been provided for
the proposed EE project.
(Source:
https://www.ingaa.org/File.aspx?id=24732)
1. How do these risk factors specifically apply to the Energize Eastside project? Design for corrosion
mitigations must be included.
2. Assuming the soil resistivity changes along the route, we need soil resistivity measurements for the
length of the project in 1/8-mile increments.
3. Soil chemistry can corrode pipelines independent of electrically induced corrosion. Are corrosion
risks due to soil chemistry and electrical coupling additive?
PSE has sought to allay concerns about electrically induced corrosion by mentioning the “cathodic
protection program” used by Olympic Pipeline Company to counter the electric field. However, the
DNV-GL report indicates that such programs are not a panacea: “DC corrosion protection utilizes a
system of corrosion resistant coatings and a cathodic protection system to provide electrochemical
protection at coating holidays to reduce corrosion rate. However, AC corrosion is possible even in
the presence of cathodically protected DC potentials… AC accelerated corrosion has been
recognized as a legitimate threat for collocated steel since the early 1990s, after several occurrences
of accelerated pitting and leaks, ultimately associated with HVAC interference, were reported on
cathodically protected pipelines.”
4. Will Olympic’s cathodic protection program be redesigned to counter the corrosive effects of the
proposed 50% increase in current?
Olympic has been in violation of safety regulations governing their cathodic protection program for
years. The company is not contesting a final determination of these violations by the Office of
Pipeline Safety. (Source:
http://primis.phmsa.dot.gov/comm/reports/enforce/documents/520155014/520155014_Final%20
Order_01132016.pdf)
5. Given past violations, what assurances does the public have that Olympic will remain vigilant in its
implementation of the cathodic protection program?
3.4. Inadequate arcing risk mitigation:
An electric current flowing through a downed high-voltage power line can arc into a pipeline and rupture the casing.
This risk is described in the DNV-GL report: “[A] direct arc to a collocated pipeline is possible, which can result in
coating damage, or arc damage to the pipe wall up to the point of burn-through. Even if an arc is not sustained long
enough to cause burn through, a short duration elevated current can cause molten pits on the pipe surface that may
lead to crack development as the pipe cools.”
A Bellevue resident Lloyd Arnesen describes an accident that occurred near his backyard in the Bridle Trails
neighborhood. A 115 kV transmission line operated by PSE fell during a windstorm, and an electric current arced into
the Olympic pipeline. When it was later inspected, the damage to the pipeline was severe enough to warrant
shutting down the 400-mile pipeline so the damaged section could be replaced.
Mr. Arnesen and his neighbors were fortunate. Residents of Mamaroneck, New York and Shively, Kentucky have
experienced pipeline ruptures due to electric arcing in recent years. DNV-GL says the risk of rupture increases for
higher voltage and current, both of which will significantly increase under PSE’s proposal.
1. What steps will PSE take to minimize the possibility of potentially catastrophic pipeline rupture due
to arcing of a downed electric pipeline?
Arcing is a concern during a large earthquake in the Puget Sound region, an event with an 80%
chance of occurring during the lifetime of this infrastructure. The Seattle Fault runs roughly parallel
to the I-90 freeway, perpendicular to the path of both the pipelines and PSE’s transmission line.
(Source: http://www.seattletimes.com/seattle-news/science/the-really-big-one-get-ready-now-
quake-experts-advise/)
Seattle Fault running perpendicular to the power line and pipeline corridor
2. What specific steps will PSE and the Olympic Pipeline Company take to defend our community
against potentially catastrophic fires following a significant earthquake? Can this project be designed
to reduce the existing danger rather than increasing it?
3.5. Inadequate lighting strike risk mitigation:
Safety experts are becoming more aware of the risk that lightning
poses to pipelines. On June 12, 2010, lightning struck a pipeline in
Utah and spilled over 25,000 gallons of crude oil into Red Butte
Creek. On September 29, 2013, a leak was discovered in an
underground pipeline in North Dakota. Over half a million gallons
of oil leaked through a quarter-inch hole caused by lightning.
(Sources:
https://en.wikipedia.org/wiki/Red_Butte_Creek_oil_spill,
http://fuelfix.com/blog/2013/10/31/lightning-may-have-caused-
north-dakota-oil-spill/)
Although lightning is not common in the Eastside area, the risks
were demonstrated on March 13, 2016 when a single lightning
bolt exploded a tree in the Somerset neighborhood within 100 feet
of the Olympic Pipeline. If a metal pole had been nearby, it is likely
that the lightning would have discharged into it and subsequently
flowed from the base of the pole into the pipeline. PSE says the
company will mitigate this risk using grounding wires and other
strategies. These mitigations have not been described in detail or
included in the visual simulations of the project.
Lightning exploded a tree near the Olympic
Pipeline March, 2016.
4. How will the public be protected from pipeline accidents stemming from lightning striking nearby steel
poles?
5. If grounding wires are used, will they stay within the corridor? What will they look like?
6. Do these strategies offer complete protection or partial mitigation?
4. The EE proposal has an inadequate accident response plan:
The consequences of a pipeline explosion anywhere along the densely populated route of the new transmission
lines is difficult to imagine. Although the Bellingham fire provided a hint of the potential devastation, it occurred in a
lightly populated area and was somewhat contained by the topography of a creek bed.
4.1. Inadequate plan to evacuate/protect children attending schools:
The proximity of schools to the proposed route is of special concern. For example, the California Code of Regulations
will not allow a school to be sited within 1,500 feet of a hazardous liquid pipeline: “Safety is the first consideration
in the selection of school sites. CCR Title 5, Section 14010(h) states “the site shall not be located … within 1,500 feet
of the easement of an above ground or underground pipeline that can pose a safety hazard as determined by a risk
analysis study, conducted by a competent professional.” (Source:
www.cde.ca.gov/ls/fa/sf/documents/v1prtocolsec1.doc)
In Renton, the Sierra Heights Elementary School is located 225 yards from the Olympic pipelines, less
than half the distance California safety codes require between schools and hazardous liquid pipelines.14
PSE proposes to install a new pole approximately 7 feet from one of the pipelines at this location. This is
less than the minimum separation of 13 feet recommended by PSE’s pipeline safety consultant, DNV-GL. No
precautions and evacuation procedures are planned or in place for schools near the pipeline.
4.2. Inadequate accident and disaster response planning:
The Bellevue Fire Department is well-acquainted with the risk posed by the Olympic Pipeline running through
Eastside neighborhoods, as described in the department’s Standards of Response Coverage: “Given that pipeline
incidents continue to occur in this country, and many for undetermined reasons, the community is still at risk. The
combination of: a highly flammable liquid, in large quantities, and in urban environment translates into a significant
consequence risk that approaches the ‘catastrophic’ level.”
The ignition of a liquid fuel pipeline has greater destructive potential because tens of thousands of gallons of
burning liquid don’t stay in one place. A river of fire could flow through the neighborhood, igniting everything in its
path. Burning jet fuel is particularly troublesome, because it can’t be extinguished with water. A special kind of foam
called “AFFF” is required. AFFF is not as readily available as water, which could lengthen response times and expand
the radius of damage. However, as the excellent guidelines published by the New Mexico Public Regulations
Commission make clear, foam cannot be used near electric infrastructure because it is conductive, posing risk of
electrocution to firefighters. (Source:
http://www.nmprc.state.nm.us/transportation/pipeline/docs/Electrical_Safety_Handbook_for_Emergency_Respon
ders_2013.pdf)
The possible paths to disaster are numerous. For
example, consider what might happen if a fire
starts, for whatever reason, in the utility corridor.
Smoke has higher conductivity than air, increasing
the danger of electric arcing from the lines to the
ground and into the pipeline. Arcing has been
implicated in pipeline failures. A breach would
add staggering amounts of fuel to the burning fire.
Firefighters would not be able to approach the
transmission lines closer than 50 feet to avoid
electrocution due to smoke arcing. The New
Mexico Commission illustrates this concern with
the diagram shown at the right.
If firefighters aren’t allowed to approach the transmission lines closer than 50 feet, what about residents who
live only 25 feet from the line in many places? Will they need to watch their homes burn from a distance to
avoid electrocution?
1. What disaster response plan will be put in place to minimize the loss of life and property from a
pipeline breach?
2. What programs and special training will be undertaken to proactively reduce the safety risk across
PSE, Olympic Pipeline Company, the City of Renton, schools, churches, residents, and other
municipalities and regional partners?
3. What plans and programs will the Renton Fire Department and the Olympic Spill Response team
have regarding informing and preparing the public, the schools and churches and emergency
responders?
5. The EE evaluation of risk does not stand up to independent review:
5.1. According to a review by Accufacts, Inc. of EDM Services’s “Technical Report, Pipeline Safety and Risk of Upset,”
which was included in the EIS, Accufacts states, EDM’s “attempts to characterize the impact area in the
Technical Report are unrealistically small. … (and the) pipeline elevation profile is neither discussed nor
proved.”
5.2. Accufacts, Inc. also notes that “Risk probabilities derived from industry-wide databases do not represent the
risks that may exist to a specific pipeline operation as management safety cultures can vary widely.” (Source:
Accufacts Review of Puget Sound Energy’s Energize Eastside Transmission project. For City of Newcastle, page
7-9, review the EDM study)
6. There is reasonable precedent for high safety concern:
6.1. During the past 16 years, almost 400 pipeline leaks and fires have occurred in the U.S. resulting in dozens of
lives lost and millions of dollars in property damage. The chart below compares the different types of failure for
227 incidents with an identified cause.
The sources of pipeline leaks include:
1. 31% - Defects in seams and welds, and damage
caused during transportation or installation
2. 26% - Damage inflicted by construction
equipment and other kinds of forceful contact
3. 22% - Internal and external corrosion
4. 12% - Accidents during maintenance or
insufficient maintenance programs
5. 5% - Stresses caused by weather, water, and
earth movement
6. 4% - Other causes such as malicious acts,
lightning, and high-voltage arcing
(Sources: http://www.bp.com/content/dam/bp-country/en_us/PDF/Pipelines/olympic-map.pdf;
https://en.wikipedia.org/wiki/List_of_pipeline_accidents_in_the_United_States_in_the_21st_century)
6.2. The Bellevue Fire Department describes the possibility of a pipeline rupture in a densely settled area as
“catastrophic.” Further they state “the USGS estimates that there is an 84% chance of an interplate earthquake
of magnitude 6.5 or greater occurring within the next 50 years.” It is well known that we are overdue for
significant earthquake events in our area. (Source:
https://fire.bellevuewa.gov/UserFiles/Servers/Server_4779004/File/Fire/Fire%20PDFs/Standards%20of%20Cov
erage.pdf, pages 64-66; Source: https://fire.bellevuewa.gov/emergency-management/hazards/earthquakes).
The City of Renton Fire Department has done no evaluation of this project themselves.
6.3. PSE and Olympic Pipeline have a history of accidents and maintenance missteps:
6.3.1. June 10, 1999, a gasoline pipeline operated by Olympic Pipeline Company exploded in Bellingham,
Washington's Whatcom Falls Park. Three people died in the accident
6.3.2. March 9, 2016, an abandoned PSE gas line caused an explosion in the Greenwood, Seattle neighborhood
that injured nine firefighters, destroyed three businesses and damaged several others.
6.3.3. In 2014 a stress-induced pinhole leak in the pipeline occurred in Renton, shooting flames twenty feet into
the air and sending three firefighters to the hospital. (Source
http://www.seattlepi.com/local/article/Wear-caused-gas-leak-in-Olympic-pipeline-1145599.php)
6.3.4. In the Final Order from Office of Pipeline Safety, Jan. 13, 2016, “[Olympic Pipeline violated three safety
regulations] by failing to correct identified deficiencies in corrosion control within a reasonable time and to
take prompt action to address all anomalous conditions.”
PSE says, “We have done this before,” “we have a good relationship with the Olympic Pipeline Company,
and we are a gas company, too.” In other words, ‘trust us.’ But PSE does not tell us they that in 2008 they
were fined a record $1.25 million by the Washington Utilities and Transportation Commission for having
falsified gas pipeline safety inspection records over a span of four years!
Olympic pipeline explosion in Bellingham in 1999
Post-explosion damage along Whatcom Creek
A Different Conclusion
No assessment of pipeline safety during and after construction was completed for the City of Renton. No assessment
of emergency response was completed. Safety and resiliency risks far outweigh any reliability benefit of the Energize
Eastside proposed solution. PSE has not adequately considered lower risk alternatives. The proposed solution is not
safe or prudent for citizens and must be rejected.