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Pg 1 of 58
From:
Todd
Andersen
&
Jennifer
Steinman
&
Ryan
Andersen
residents
and
homeowners
at
4419
138th
Ave
SE
Bellevue
WA
98006.
Questions/comments
on
EE
EIS
and
Pipeline
Safety
Reports
and
related
for
Phase
2
2017
EE
EIS
Submitted
June
21,
2017
Attachments:
1.
Energize
Eastside
and
seismic
risks
in
South
Bellevue.pdf
paper
by
James
Sweet,
PE
(Professional
Engineer)
is
a
retired
engineer
who
moved
to
South
Bellevue
with
his
family
in
1960.
2.
P2-‐43_Fumio
20Kajiyama.pdf
A
Japanese
AC
inducted
corrosion
paper.
3.
PipelineTechJoural(foundlooking$..EN15280)ptj-‐1-‐2015.pdf
First
let
me
thank
City
Staff
and
associated
contractors
for
continuing
the
massive
fraud
and
incompetence
(IMO)
that
PSE
started
with
Energize
Eastside
and
the
former
are
continuing
with
this
is
draft
Phase
2
EIS.
It
can
only
lead
to
a
wholesale
reform
of
Bellevue
City
government
and
a
significant
reorganization
of
City
of
Bellevue
government
and
our
energy
infrastructure,
for
which
I
will
be
eternally
grateful.
We
request
immediate
halt
to
EE
EIS
for
massive
incompetence
and
blockage
of
information
flow
and
request
at
restart
of
EE
EIS
with
new
personnel
at
City
of
Bellevue
and
new
competent
contractors.
The
CoB
has
not
followed
its
electrical
reliability
reports
from
Exponent
that
the
City
hire
a
skilled
technical
utility
electric
power
engineer
to
help
guide
its
hiring
of
qualified
resources.
Hire
competent
staff
from
sources
that
do
not
have
a
economic
interest
in
continuing
the
massive
fraud
of
fossil
fuels
industry.
Good
sources
include
Pacific
Northwest
Laboratories,
National
Institute
of
Standards
and
Technology,
scientist
and
engineers
at
US
Navy
Laboratories.
The
reason
for
the
restart
demand
for
EE
EIS
is
as
follows
(Items
1.xx
which
also
include
comment
and
question
for
the
EE
EIS)
1.
The
incompetence
of
the
overall
Energize
Eastside
(EE)
and
its
review
including
this
Phase
2
Energize
Eastside
EIS
is
so
high
that
I
request
that
the
process
be
restarted
with
new
City
management
skilled
at
hiring
the
necessary
resources
to
review
the
safety
impact
of
doubling
the
voltage
over
two
highly
volatile
jet
fuel,
aviation
gas
and
auto
gasoline
pipelines.
And
to
included
assessing
the
impacts
of
increased
energy/communication
infrastructure
concentration
as
dozen
of
papers
by
US
Congress,
Congressional
Research
Service
and
etc
warn
of
include
Puget
Sound
Energy’s
infrastructure.
PSE
&
idiocy
such
as
EE
was
specifically
targeted
by
recent
Dept
of
Energy
Clear
Path
IV
exercise
for
a
Pacific
NW
slip
fault
and
the
follow
on
FEMA
Cascadia
Rising
exercise
which
gave
PSE
and
all
Puget
Sound
entities
a
grade
of
F.
See
www.fema.gov/cascadia-‐rising-‐2016
and
the
massive
amount
of
documentation.
Clear
Path
IV
included
representation
from
10
Federal
agencies,
seven
states,
five
local
governments,
15
oil
and
natural
gas
companies,
18
electric
utilities,
six
trade
associations,
and
four
state
associations
with
more
than
175
participants.
Portland
Oregon
alone
is
expecting
700
breaks
in
its
~300psi
Pg 2 of 58
water
main
from
Mt
Hood.
The
Eastside’s
aged
45
yr
old
and
52
year
old
BP
Olympic
Pipelines
operating
at
300
to
500
psi
and
improperly
inspected
and
improperly
maintained;
directly
under
PSE
AND
SCL
high
power
lines
will
receive
much
greater
stress
corrosion
and
increased
AC
inducted
corrosion
from
a
doubling
of
the
overhead
voltage
from
115kV
to
230kV.
Why
shouldn’t
PSE
committee
fraud?
The
economic
case
of
$3
million
maximum
penalties
by
federal
law
even
for
outright
fraud
resulting
in
multiples
death
is
trivial
when
the
interest
&
profits
on
the
$280
million
un-‐need
power
lines
will
total
well
over
$1
billion
dollars.
Just
yesterday
June
19
2017
we
have
another
example
of
PSE’s
fraud
with
the
settlement
of
Greenlake
area
of
Seattle
natural
gas
explosions.
Fine
was
$1.5
million,
½
the
maximum
allowable
no
matter
how
much
fraud
and
how
many
deaths.
40,000
uninspected
natural
gas
lines.
What
are
the
risks
given
PSE
has
no
economic
incentive
to
do
the
right
thing
and
Macquarie
has
lost
mass
amounts
on
it
investment
in
PSE
that
PSE
will
just
pay
the
fine?
What
is
the
resulting
damage
PSE
could
cause
under
this
very
real
world
case?
Alternatively
see
what
DOE
scientists/Engineers
and
NY
ConEd
(a
former
giant
of
fossil
fuel
industry
corruption,
see
the
1940
Spencer
Tracy
film
Edison
the
Man
particularly
the
NY
City
Council
scenes,
now
good
guy
as
Goldman
Sach
etc
demands
it)
and
Southern
Cal
Edison
see
as
the
solution
as
grid
storage.
And
here
is
one
commercially
fielded
example
the
DOE
calls
out
from
Mukilteo,
WA
Uni
Energy
Technologies
with
100MW
storage
already
sold,
all
to
Germany.
This
does
not
include
the
dozen
of
others
including
PSE’s
owner
Macquarie
investing
$200
million
in
a
grid
storage
company
the
far
cheaper
and
deconcentration
of
energy
infrastructure
solution
vs
the
more
expensive
and
more
concentration
solution
represented
by
PSE’s
EE.
www.greentechmedia.com/articles/read/Advanced-‐
Microgrid-‐Solutions-‐Gets-‐200M-‐From-‐Macquarie-‐to-‐Finance-‐Aggregate
www.energy.gov/oe/articles/unienergy-‐technologies-‐and-‐pnnl-‐recognized-‐
advancing-‐energy-‐storage-‐national-‐level
www.energy.gov/oe/articles/oe-‐announces-‐investment-‐new-‐research-‐improve-‐
grid-‐reliability-‐and-‐resilience-‐through
Here
is
PSE’s
owner
Macquarie
company
Advanced-‐Microgrid-‐Solutions
bidding
NY
CodEd
solution.
www.greentechmedia.com/articles/read/New-‐Yorks-‐
ConEd-‐Is-‐Building-‐a-‐Virtual-‐Power-‐Plant-‐From-‐Sunverge-‐Energy-‐Sto
A
competitor
to
Advanced-‐Microgrid-‐Solutions
is
Stem
....“Stem
is
already
participating
in
an
85-‐
megawatt
project
with
Southern
California
Edison
to
provide
local
and
system-‐wide
capacity
for
the
utility.”
Macquarie
is
desperate
not
to
be
left
behind
but
more
than
will
to
shove
EE
shit
down
PSE
rate
payers
throats,=
see
Edison
Instutue
ref
later
in
this
write
up.
1a.
The
City
of
Bellevue
staff
and
contractors
as
well
as
PSE
and
contractors
have
repeatedly
and
actively
inferred
with
open
meeting
process
including
EE
EIS
slapping
the
camera
out
of
citizens
hands
and/or
blocking
who
where
attempting
to
document
the
fraudulent
and/or
false
and
or
misleading
information
that
City
of
Bellevue
EIS
staff/contractors
and
PSE/PSE
contractors
are
verbally
putting
out.
1b.
The
person
responsible
for
slapping
the
camera
out
of
my
hand
directly
is
Carol
Helland
the
City
of
Bellevue
lead
manager
for
the
EE
EIS
process
and
responsible
authority
for
its
impartial
conduction.
This
is
all
on
video.
Carol,
Pg 3 of 58
unbelievably,
is
an
attorney
and
further
adding
to
the
proof
that
the
EE
EIS
is
not
being
fairly
and
honestly
being
conducted.
1c.
The
quality
of
the
EE
EIS
is
so
incompetent
on
numerous
fronts
that
it
is
clear
it
is
just
a
white
wash
and
completely
lacking
in
real
facts
to
the
safety
and
need
and
real
life
alternatives.
The
simple
fact
of
the
EIS
review
is
that
experts
not
catching
the
issues
with
PSE’s
fraudulent
pipeline
safety
report
by
DNV-‐GL
using
natural
gas
pipeline
engineering
recommendations
(the
2015
INGAA
report
“Criteria
for
Pipelines
Co-‐Existing
with
Electric
Power
Lines,”)
as
there
are
no
government
standards
yet
in
effect
for
liquid
pipeline
for
corrosion
including
stress
corrosion.
The
DNV
never
detail
the
corrosion
risk
and
even
get
the
personel
safety
risk
wrong.
The
DVN-‐Gl
pipeline
safety
report
is
a
warmed
over
copy
of
a
similar
EIS
of
the
State
of
Minnesota,
likely
why
the
EE
version
has
so
many
errors.
https://mn.gov/commerce/energyfacilities/documents/34079/Public%20Commen
ts%20S2%20to%20W.pdf
Nor
did
the
City
of
Bellevue
experts
catch
that
the
wrong
“standards”,
actually
not
standards
at
all
as
the
authors
themselves
state
that
the
DNV-‐GL
pipeline
safety
report
is
using
recommendations
from
a
report
(the
INGAA
report
)
written
by
the
same
highly
inexperienced
and
technically
deficient
engineers
that
wrote
the
DNV
report.
And
if
that
is
not
enough
DNV-‐GL
does
even
follow
the
INGAA
recommendations
(pg58of66)
“there are no established criteria for AC corrosion control
provided in SP0177-2014. Further, this standard states that the subject of AC corrosion is “not
quite fully understood, nor is there an industry consensus on this subject.
“
True
and
BS
what
is
what?
The
City
of
Bellevue
EE
EIS
also
called
“experts”
even
stated
on
video
that
PSE’s
DNV-‐GL
pipeline
safety
study
uses
Pipeline and Hazardous Materials Safety
Administration (PHMSA) regulations when in fact it does not contain one word of
Pipeline and Hazardous Materials Safety Administration (PHMSA) or regulations
relating to it.
PSE or DVN-GL chose the NACE Report 35110, “AC Corrosion State-of-the-Art:
Corrosion Rate, Mechanism, and Mitigation Requirements” see screen shot below. Many
things wrong with this. First this is not a Standards document!! Even the authors of the
Pg 4 of 58
the
DVN
report
authors
says
so
in
a
natural
gas
pipeline
report
that
they
reference,
the
2015
INGAAC
report
screen
shot
below
see
first
yellow
high
lighting.
What
is
particularly
concerning
is
that
the
they
and
NACE
readily
admits
that
the
AC
corrosion
is
not
well
understood
(by
them
but
not
other
including
the
US
Navy)
,
see
red
underline
below
for
the
authors
of
the
DNV
report
which
also
wrote
the
below
INGAAC
report.
The
“protected
level”
is
the
DNV
authors
quote
from
this
2006
report
EN15280,
“Evaluation
of
AC
Corrosion
Likelihood
of
Buried
Pipelines
Applicable
to
Cathodically
Protected
Pipelines,”
is
for
protection
against
AC
corrosion
(nothing
could
be
further
from
the
truth
but
let
got
with
it)
at
according
to
the
British
Standard
which
the
author
mistakenly
call
the
European
Standard
“European Standard CEN/TS 15280:2006”.
It
a
British
Standard.
Please
have
EE
EIS
clarify
what
is
the
USA
Federal
Standard
and
WA
state
standard
for
Evaluation
of
AC
Corrosion
Likelihood
of
Buried
Pipelines
Applicable
to
Cathodically
Protected
Pipelines.
What
are
the
rule/regulations?
First
this
EN15280
standard
is
contradicted
by
the
real
Eurpean
Standard
the
ISO
standard
per
see
paper
which
quotes
the
European
Standard
as
3
A/m2
is
at
high
risk
of
corrosion.
CP
means
catholic
protection
which
OPL
are
using.
Pg 5 of 58
Please
have
/
what
is
the
“protection”
level
for
all
standards
bodies
USA
British,
EU,
Japan?
Why
on
Pg4/49
the
DNV-‐GL
pipeline
safety
report
reference
a
NACE
group
that
has
be
inactive
for
7
years
and
why
has
the
DOD
and
ANSI
have
not
adopted
nor
approved
it
use?
See
below
screen
shots.
IS
it
because
NACE
is
the
laughing
stock
of
the
corrosion
world?,
at
least
in
the
US
Navy,
minus
non
technical
DOD
managers
desperate
for
a
job
function.
NACE Report 35110, “AC Corrosion State-of-the-Art: Corrosion Rate, Mechanism, and
Mitigation Requirements”5: 5=
NACE
TG
327,
“AC
Corrosion
State-‐of-‐the-‐Art:
Corrosion
Rate,
Mechanism,
and
Mitigation
Requirements”,
NACE
Report
35110,
2010.
This
below
gives
father
below.
www.nace.org/cstm/Technical/Directory/Committee.aspx?id=64105b41-‐60ef-‐
db11-‐9194-‐0017a4466950
and
here
is
what
IEEE
says
Pg 6 of 58
Pg 7 of 58
Please
detail
why
the
DOD
refuses
to
use
the
incomplete
and
insufficient
NACE Report
35110, “AC Corrosion State-of-the-Art: Corrosion Rate, Mechanism, and Mitigation
Requirements”5
What
governing
body
said
to
use
NACE,
a
for
profit
corrosion
company
which
can't
even
keep
it
plaque
for
work
at
the
Statue
of
Liberty
from
corroding?
See
screen
shot
below.
Why
is
this
the
non
standard
“standard”
per
the
authors
of
the
DVN
report
used
by
the
same
authors
for
the
EE
DVN_GL
pipeline
safety
report?“*
pg
58/66(INGAA)
While not a Standard Practice document, NACE published “AC Corrosion State-of-the-Art:
Corrosion Rate, Mechanism, and Mitigation Requirements”1 in 2010, providing guidance for
evaluating AC current density, and providing recommended limits as discussed in Section
3.3.1.1.,
The
above
are
just
safety
limits
so
pipeline
personnel
are
not
electrocuted!!
WHAT
DOES
TABLE
E1
LOOK
LIKE
FOR
CORROSION
including
stress
corrosion?
1d.
During
with
extremely
short
period
of
time
to
review
the
City
held
back
experts
at
the
third
and
final
EE
EIS
Phase
2
open
house
so
that
citizens
could
not
fully
record
the
lack
of
technical
expertise
and
engineering
knowledge
of
the
EE
EIS
and
supporting
documents
and
the
Federal
standards
and
the
lack
of
governing
regulations
and
the
feasibility
of
safety
parallel
collocating
high
power
electrical
transmission
line
and
highly
volatile
gasoline
pipelines
for
18
miles
not
to
mention
natural
gas
pipelines.
None
of
the
experts
at
the
second
EE
EIS
meeting
in
Bellevue
May
29,
2017
were
present
at
the
third
in
Kirkland
on
June
3
2017
as
citizens
were
starting
to
piece
together
how
little
the
so
called
experts
knew.
Surprisingly
the
little
amount
videoed
of
EE
EIS
“experts”
at
the
May
29th
Bellevue
EE
EIS
shows
a
shocking
level
of
understanding
of
the
pipeline
safety
issues
for
which
PSE
Pg 8 of 58
commissioned
the
DNV-‐GL
a
safety
report.
Why
were
the
experts
held
back
and
not
present
for
the
Kirland
meeting?
1e.
The
9%
increase
in
risk
is
so
fraudulently
determined
that
it
alone
disqualifies
the
contractors
producing,
contractors
reviewing
and
City
of
Bellevue
staff
from
further
work
on
the
EE
EIS
and
a
full
restart
of
the
process.
One
such
example
is
only
a
claimed
9%
increased
risk
going
from
230kW
lines
from
115kV.
This
9%
number
is
highly
fraudulent
from
dozens
of
factors
let
us
just
review
the
top
ones.
First
ESA
(the
contactor)
just
selectively
chose
the
pipeline
incidents
that
are
not
representative
of
EE.
Ones
representative
are
pipelines
the
parallel
collocation
of
pipelines
with
high
voltage
power
lines
for
decades.
Including
pipelines
without
the
high
power
voltage
lines
115kV
or
greater
is
so
statistically
invalid
that
it
is
fraud
or
highly
incompetent
as
it
massively
suppresses
the
increase
in
risk
by
many
orders
of
magnitude.
Second
I
believe
I
have
the
City’s
“experts”
on
video
saying
that
they
could
not
get
any
information
on
jet
fuel/aviation
gas/car
gasoline
pipeline
lines
parallel
collocated
with
115
KV
or
any
high
power
transmissions
lines.
And
thus
claims
he
has
to
use
statistically
irreverent
non
AC
inducted
pipeline
data.
If
so
picking
incidents
from
non
located
pipelines
is
equally
invalid
as
picking
incidents
from
children
drinking
with
paper
soda
straws.
Third
the
EE
EIS
“experts”
claim
that
new
and
unreleased
safety
rules
and
inspection
criteria
from
PHMSA
make
it
statistical
validation
to
exclude
incidents
pre
2010
for
pipelines
that
are
decades
old.
Please
detail
exactly
what
new
pipeline
updates
to
regulations
and
inspections
are
in
place
and
were
used
for
the
EE-‐EIS
pipeline
safety
study
and
how
the
lack
of
little
no
enforcement
make
this
a
valid
assumption?
Once
again
demonstrated
by
PSE
being
criminally
fined
for
lack
of
inspecting
40,000
natural
gas
pipe
lines
on
June
19,
2017.
What
allows
for
pipeline
issues
prior
to
2010
to
be
ignored?
vastly
suppressing
the
safety
issues.
place
inspection
criteria?
Why
is
the
most
sophisticated
pipeline
Risk Criteria by Jurisdiction of the
Eurpean Union left out and only cherry pick ones left pg 434/574. Please detail the City
references for each of the listed Risk Criteria by Jurisdiction. Trusting a demonstrably
incompendent and likely fraudulent fossil fuel service company like EDM Services is
unacceptable
1f.
unbelievably
incompetent
use
of
basic
documentation
procedures
followed
to
allow
citizens
to
timely
and
cost
effectively
uncover
the
vast
amount
of
fraud
the
EE
EIS
and
related
report
contain.
Only
a
mass
listing
of
references
with
no
tied
back
to
the
574
pages
of
information/garbage/fraud.
Please
correct
and
reissue
the
document
and
expand
citizens
review
time.
Zero
documentation
of
references
to
claims/assertion/or
simple
reference
provided.
One
of
thousands
of
examples
is
example
see
ref
3
of
9%
pg
438
of
574.
Search
for
any
“ref
3”
or
like
and
zero
result
to
see
the
math
or
statistical
procedure
(non
math)
provided
for
this
9%
increase
determination.
Please
detail
the
math
or
other
fraud
to
get
the
9%
number.
The
“Source:
EDM
Services,
2017.
Figure
3.9-‐11.
Change
in
Incident
Frequency”
on
pg
437of
574
are
just
assertions.
Please
detail
how
the
numbers
are
arrived
at.
One
could
just
as
easy
assert
100%
increase
risk
in
disaster
based
on
evidence
EDM
and/or
ESA/
other
contractor
have
provided.
1g.
Figure
3.9-‐8.
Pg
xxof574
contains
no
internal
corrosion
only
external
consideration
which
can
in
fact
be
the
dominate
issue.
The
fluids
flowing
through
the
pipe
in
fact
contain
lead,
water
vapor
and
other
material
in
minuscule
quantities
Pg 9 of 58
that
can
be
dominate
corrosion
factors.
What
are
the
corrosion
and
other
impacts
of
this?
AAA.
Please
detail
the
maximum
federal
penalty
if
convicted
fraud
and
other
crimes
committed
for
profit
utilities
and
the
effects,
impact.
What
is
increased
risk
borne
by
the
Eastside
for
the
maximum
federal
penalty
for
fraud
of
$3
million
no
matter
the
deaths
or
damage?
Please
detail
PSE’s
and
Macquarie
criminal
and
civil
penalty
history.
What
is
its
impact
on
risk
factors
and
repeat
offender
vs
new
and
those
risks
factors
on
safe
construction
and
operation
of
EE
and
possible
negative
impacts
of
repeat
of
fraud?
Please
denote
the
10
worse
possible
case
safety
of
fraud
PSE
could
commit
as
well
as
BP
given
they
are
both
repeat
offenders.
It
critical
that
PSE
and
owners
past
history
be
taken
into
account
on
safety
risks.
BBB1 pg 418 and on/574 “The inspection reports on UTC’s website for Olympic’s
facilities in Washington State are only available for the years 2012 through 2016.” This
unacceptable and insane these pipes are +45-55 yrs old with massive amount of
accumulated wear and corrosion. Are these reports are available by going to the WA
UTC? Why are they not available farther back? By statute? Where is the Newcastle
Olympic pipeline fire from a test pipe that ignited solely from the corona discharge
energy same as the massive fire which will result from a 20”/16’’ main pipeline
breakage.
BBB1.2 EDM Services
assumption
of
a
spill
reaching
372,162 gallons
is
ball
park
correct.
All
other
are
complete
and
utter
nonsense.
EDM Services
is
simply
pulling
crap
out
of
their
orifices.
As
a
form
US
Dept
of
Navy
Survivability
technical
manager
and
fuel
air
explosive
(FAE
weapons)
engineer
a
10,000 gallon jet fuel spill
will easily have flames hundreds of feet high if not over a 1000 feet high vertically.
Horizontally the heat driven wind vortexes will drive the fuel thousands of feet from the
spill on a flat surface within a minutes if not seconds. Limiting our Navy testing to just
40 gallons of jet fuel we could easily get peak fire heights of 100 feet. Please include
details of actual fuel firex not just made up crap. Also detail the toxic plumes for the
burning of homes/business and electronic equipment. The recent massive fire in a
Canadian petroleum town (2015 or 16) prevented the return of hundreds of home owners
not burned down for months due to the toxics from the plume from the electronics from
the homes that did burn. Who the hell is the reference CDE, 2007? Really California
Department
of
Education
(CDE
2007
and
CDE
2005).
February
2007.
Guidance
Protocol
for
School
Site
Pipeline
Risk
Analysis.
and is used to spew all kind of bullshit in the EE EIS
report. Was the CDE report done by Exponent or other fake science for hire like DNV-
GL. Exponent hired by the fossil fuel industry to provide fake science to California
legislators to say MTBE is perfectly safe well within societal risk factors
Exponent is as corrupt/criminal science for hire as DNV-GL (PSE/BP Olymic pipeline
safety report which is unbelievably fraudulent). Exponent was the “independent experts”
paid for by the oil industry for telling the California Legislature that MTBE was a safe
fuel additive for auto gasoline only to have it pulled years later for its toxicity.
Pg 10 of 58
Exponent, like DVN-GL, starts with the answer the customers wants and
generates spin and irrelevant science to support leaving out the real facts.
For 1/10th of the MTBE story google (Exponent MTBE and “Doubt is Their
Product: How Industry's Assault on Science Threatens Your Health”) The
other 9/10th of the story is oil industry wanted to get MTBE got into autos to
reverse it being banned by the aircraft manufactures. The piston driven
aircraft industry banned MTBE as a replacement to lead just 8 hrs after first
testing its use in 1992. Why? Because of its toxicity. Aviation fuel was
getting 10 year waivers (from themselves as they control the astm petroleum
committees with user having only 20% of votes) of to continue use of toxic
lead since lead was banned in car fuel in 1978. The aircraft industry wanted
ETBE as it far safer/better/cheaper. If that happened the oil industry lost at
least 1/3 of its aviation fuel business (piston not jet) to ETBE which was made
via agriculture/distilling vs MTBE which was made from fossil fuels. The oil
industry was desperate to get MTBE out in the market as the “non toxic
alternative” and thus the fake science. By the way piston aircraft still use
leaded fuel, toxic to kids at any level and way health issue 2 miles around all
airports are significantly higher including lead levels....
Really you are going to use a California
Department
of
Education
report
to say it is ok not to
get real pipeline safety information? (pg 432/574) “In the risk assessment field, it is not
uncommon for certain pipeline information to be unavailable from the pipeline operator
due to proprietary or security reasons (CDE, 2007). (CDE, 2007)=bullshit. It is not ok
for the EE EIS not to use actual pipeline condition and remaining lifetime facts which
under a 230kV stress could result in a massive leak in just few years if not months. What
requests were made to BP in writing and BP responses?
Pg 11 of 58
BBB1.3
The
wetter
the
day
the
bigger
the
fire
max
width,
they
are
never
a
circle.
Complete
BULLSHIT
even
for
a
500
gallon
fire!!!
See
screen
shot
below.
Drawing
assumes
a
flat
terrain
which
is
less
than
1%
of
the
18
miles.
Please
correct
with
real
data
of
fuel
fires
that
are
running
there
will
never
be
stationery
“pool
fire”
in
the
terrain
under
review.
How
are
how
fuel
fires
are
fought
in
detail
and
how
useful
is
water
with
fuel
fires?
Please
detail
the
numerous
area
where
the
leaks
could
run,
ie
paved
streets,
storm
drains
(please
detail
the
impact
of
the
resulting
days
if
not
weeks
of
ullage
explosionS
which
will
occur
in
the
storm
drains
(particularly
in
hilly
terrain=
elevation
delta
of
10
feet
or
greater)
and
the
cost
to
replace
fractures
in
light
weight
concrete
pipes
used
for
storm
drain
pipes,
this
could
total
in
miles
of
storm
drain
pipe
for
each
fuel
spill
with
just
10,000
gallons.
An
earthquake
could
see
dozens
of
breaks
in
storm
drain
and
stream
beds.
Please
denote
all
crossing
of
the
above
with
major
highway
I405
I90
520
and
amount
of
fuel
to
take
down
a
interstate.
Answer
around
500
gallons.
Atlanta
had
a
simple
PVC
pipe
(empty
pipe)
fire
take
down
and
interstate
just
in
the
last
year.
Even
CARANY’s
BS
0.38
psi
overpressure
would
send
200
pound
manhole
covers
flying.
BBB1.4
Please
compare
the
recent
Space-‐X
rocket
explosion
on
the
pad
with
a
fuel
release
under
680
psig,
What
are
the
head
pressures
and
height
of
spray
and
ability
to
blow
off
3
feet
of
soil
cover,
amount
of
radiant
heat
released
per
unit
of
time
and
the
rate
needed
to
melt
the
power
lines
and
catch
trees
houses
on
fire?
Please
see
the
video
shown
on
every
TV
station
of
the
fuel
load
deflagration
on
the
Space-‐X
rocket
that
vaporized
the
paint
and
primer
on
the
adjacent
towers
in
less
than
4
seconds
(see
top
of
adjacent
tower
and
smoke
coming
off
www.youtube.com/watch?v=UKUz5ZUPqM8).
And
what
the
structural
damage
to
those
towers
was
from
radiant
heat
and
compare
for
the
EE
EIS
what
an
arc
fault
rupture
of
the
Olympic
pipeline
from
a
fallen
power
lines
both
115kV
and
proposed
230kV
and
resulting
jet
fuel
release
rates
we
have
actually
seen
in
real
life
scenarios?
Please
detail
how
many
high
power
line
drops
have
occurred
historically
in
the
PSE/BP
pipeline
right
away
and
how
long
power
to
the
line
remained
on
in
each
incident.
Please
include
the
history
of
other
pipeline/HVAC
line
drop
incident
and
impacts.
What
the
Olympic
pipeline
yellow
pipeline
patrol
aircraft
purpose
and
if
it
has
infrared
gear
for
leak
detection
for
those
not
yet
ignited?
Please
Detail
how
well
OPL’s
leak
detection
system
worked
for
the
Bellingham
WA
fire.
Aand
did
it
reach
the
8%
requirement
and
what
was
the
penality
for
not?
“Leak
detection
systems
must
be
capable
of
detecting
an
eight
percent
(8%)
of
maximum
flow
leak
within
fifteen
(15)
minutes
or
less.”
?
How
was
Bellingham
WA
leak
detected?
Also
please
detail
the
effectiveness
leak
detection
system
for
the
~2300
liquid
pipeline
spills
and
include
that
in
to
your
societal
risk
factor
analysis.
Please
detail
the
Colonial
pipeline
fire/spill
and
did
the
detection
system
there
meet
the
8%
criteria
for
leak
detection
for
that
957,600
US
gallons
spill.
Pg 12 of 58
Please
include
in
societal
risk
assessment
numbers
the
risk
of
not
having
details
on
various
pieces
of
information
which
the
draft
EE
EIS
denote
in
dozens
of
places.
The
Space
Shuttle
had
a
1:1,000,000
~calculated
risk.
Actual
facts
135
total
launches
2
failures
actual
risk
1:62.5
What
are
the
societal
risks
for
PSE
going
bankrupt
because
if
EE
is
approve
and
massive
amount
of
people
leave
the
grid
and
PSE
prices
increase
further
pushing
more
people
off
the
grid.
See
Disruptive
Challenges:
Financial
Implications
and
Strategic
Responses
to
a
Changing
Retail
Electric
Business.
http://www.eei.org/ourissues/finance/documents/disruptivechallenges.pdf
PSE
owner
Maquaire
wrote
the
dam
report
see
Exhibit
2
pg
16/26.
Why
leave
the
grid?
Per
Morgan
Stanley
and
Deutsche
Bank,
WA
is
the
last
state
to
be
in
the
money
for
solar
PV
which
it
does
in
2017,
meaning
cheaper
to
go
off
grid
than
stay.
Why?
because
solar
PV
and
storage
it
is
cheaper
and
essentially
become
a
10to15%
percent
yielding
bond.
What
are
the
societal
risks
to
this
happening?
What
are
the
risks
for
release
rate
vs
age
of
pipe
from
stress
corrosion
pipeline
breaks
for
pipes
with
HVAC
corrosion
and
those
without?
What
are
the
reasons
why
sections
of
the
pipelines
line
have
been
replaced
and
expected
remain
lifetime
of
the
old
section
of
pipes?
Pg 13 of 58
Also
what
is
the
comparison
of
the
stress
corrosions
knowledge
history
in
non
fraudulent
industries
particularly
the
US
Navy
with
that
of
the
criminal
and
fraudulent
fossil
fuels
industry?
Where
the
federal
regulator
of
the
massive
William
pipe
line
explosion
in
WA
in
2003
had
the
!@#$%
balls
to
call
stress
corrosion
a
“new
phenomenon”.
Pencil
lead
on
aluminum
aircraft
metal
is
not
a
new
effect
when
it
brittles
the
metal
and
causes
a
10
hour
old
aircraft
to
have
a
wing
rip
off
from
low
fatigue
life
and
neither
is
stress
corrosion.
The
fact
that
it
took
4
decade
before
graphite
pencils
are
banned
in
all
aluminum
manufacturing
floors
in
the
USA
is
not
“new
phenomenon”
just
age
old
ignorance
of
humans.
Please
refer
to
Williams
pipeline
explosion
elsewhere
in
this
document.
What
is
the
further
energy
infrastructure
concentration
where
Seattle
City
Light
lines
and
PSE
cross
and
the
very
low
level
of
fuel
fire
need
to
weaken
the
SCL
towers
to
collapse
and
the
impact
of
losing
both
PSE
and
SCL
lines
and
the
ramifications
of
having
the
Olympic
pipeline
shut
off
values
out
of
commission
along
with
both
lines
down?
Also
is
a
370,000
gallon
spill
is
enough
make
to
the
creek
bed
near
by
and
when
it
has
water
how
far
for
fuel
to
travel
to
shut
down
I405
highway?
Also
detail
the
escape
time
to
the
elementary
school
500
meters
away
at
the
crossing
of
SCL
and
PSE
line
(around
Renton
New
Castle
boarder.
Also
what
are
escape
times
for
Tyee
Middle
School
and
Puesta
del
sol
elementary
school
which
is
right
on
the
a
fault
line
and
Tyee
which
is
50
feet
from
the
Olympic
pipeline
,
see
attach
seismic
impacts
paper
attached
with
this
document
by
James
Sweet
PE.
When
does
the
creek
bed
by
Tyee
middle
school
has
water
in
it
as
well
a
the
dozen
of
other
creek
beds
crossing
this
EE
concentrate
energy
infrastructure
for
18
miles
allowing
very
fast
fire
spread
as
in
Bellingham?
What
is
the
ullage
explosion
potential
of
the
creek
bed
piping
and
tunneling
and
air
flow
dynamic
for
repeated
explosions
in
same
pipe
or
tunnel.
Same
for
storm
drains
particularly
on
long
slopes?
What
are
the
increased
risks
including
societal
risk
numbers
from
the
information
in
attached
James
Sweet
details
in
his
2015
paper
which
was
previously
submitted
to
the
EE
EIS
and
City
of
Bellevue
but
have
received
no
response
nor
included
analysis
in
the
EE
EIS.
Why
is
the
Energize
Eastside
(EE)
EIS
ignoring
the
risk.
What
are
the
as
increased
AC
inducted
corrosion
which
is
very
hard
to
detect
particularly
stress
corrosion?
Please
detail
the
further
risk
and
impacts
to
the
Eastside
to
PSE’s
EE
and
its
further
energy
and
communication
infrastructure
concentration
including
page
10
of
10
Tyee
Middle
and
Puesta
del
Sol
elementary
school.
Both
schools
on
a
creek
bed
which
is
often
running
with
water
which
allow
a
fast
fuel
leak
spread.
EE
is
just
solving
the
fraudulent
problem
if
two
500kV
BPA
powerlines
go
down
during
a
freak
23F
winter
and
80-‐95%
of
1.2
GW
of
peaking
plant
generation
is
off
line
and
thus
the
need
for
more
concentrated
energy
infrastructure
which
greatly
increase
societal
risk.
What
is
the
increase
societal
risk
given
EE
increase
AC
corrosion
and
Stress
corrosion
and
increase
risk
of
terrorist
attack
on
infrastructure
shutting
down
both
SEATAC
and
Portland
airport?
What
is
the
societal
risk
shutting
of
auto
and
diesel
gas
deliveries
to
southern
half
of
WA
and
Oregon?
What
is
the
increase
risk
of
while
the
BP
pipeline
are
down
and
fuel
shipment
go
to
I5
and
I405
and
risks
of
accident/
terrorist
opportunities?
What
are
the
risks
of
this
Pg 14 of 58
the
societal
risk
in
feet
of
spacing
from
pipeline/powerline
and
schools
as
security
by
obscurity?
Security
by
obscurity
never
works
just
makes
the
attackers
more
successful,
what
is
the
increase
zero-‐day
risk
of
EE’s
230kV
lines?
How
is
it
two
500kV
lines
have
to
go
down
before
the
current
EE
115kV
lines
which
never
overheat
just
the
transformers
do?
How
massively
over
built
the
current
system
is?
How
poorly
designed
is
it
given
FERC
didn’t
force
SCL
PSE
and
BPA
to
form
Columbia
grid
until
2006,
which
this
project
was
never
run
through
Columbia
Grid
organization
for
approval?
Please
expand
and
inform
the
societal
risk
section
of
the
EE
EIS
with
pipeline
and
power
line
location
rules
relative
to
schools
for
Texas
to
those
in
WA.
Texas
the
seat
of
the
criminal
fossil
fuel
industry,
has
a
quite
more
restrictive
take.
What
does
Texas
do
and
what
are
its
societal
risk
analysis
numbers?
BBB1.3
The
resulting
peak
over
pressure
0.38
psi
is
also
complete
bullshit.
Why?
The
below
is
total
bullshit,
any
of
the
these
can
be
made
to
denote
(flame
front
faster
than
the
speed
of
sound
in
the
medium)
or
deflagrate
(flame
front
slower
than
Pg 15 of 58
the
speed
of
sound
in
the
medium)
under
the
right
open
air
conditions.
Those
conditions
likehood
greatly
expand
for
deflagrations
which
have
enough
overpressure
to
kill.
Particular
with
the
massive
available
corona
discharge
energy
of
power
lines
as
a
multiple
ignition
source
greatly
boosting
overpressure.
All
can
easily
generate
over
pressure
great
enough
to
kill.
Even
a
deflagration
far
less
than
the
speed
of
sound
can
kill
via
over
pressure
alone,
all
depends.
The
scenario
is
s
light
wind
pushed
fuel
vapor
horizontal
to
ground
away
enough
from
corona
discharge
such
that
a
tail
possible
thousand
of
feet
long
form.
The
winds
stop
of
a
moment
to
allow
a
fuel
vapor
to
hit
enough
corona
discharge
energy
and
bang,
a
thousand
foot
deflagration,
much
larger
and
stronger
with
a
230
kV
corona
and
bigger
to
higher
poles.
Please
do
some
CANARY
runs
for
propylene
oxide
at
Zero
degrees
F
and
appropriate
humidity
at
such
temperature
and
tell
us
the
over
pressure
as
a
sanity
check
including
the
various
ignition
sources
tried?
I
bet
I
can
even
dig
up
video
of
real
world
results.
Hope
your
model
matches
the
real
world
facts.
As
a
fun
factoid
the
world
largest
weapons
lab
China
Lake
CA
with
hundreds
of
possible
fueling
operations
shut
down
ALL
operations
at
a
corona
discharge
level
of
2000
volts
per
meter.
The
below
are
too
limited
and
cherry
picked
values
to
cover
actual
conditions
during,
need
to
run
a
range
23F
(PSE
design
temp)
to
say
100F,
5%
to
70%
humidity
for
open
air,
storm
drains
will
completely
different.
What
are
the
corona
discharge
energy
of
powerlines
which
will
the
dominate
ignition
source
even
at
70%
humidity,
as
the
previous
New
Castle
BP
OPL
fire
as
demostrated.
BBB.2
“pg
422/574
“Note: this data set excludes incidents that were limited to pipeline facilities (e.g.,
tank farm, station equipment, pump station, appurtenance piping, and valve station)”
This
is
malpractice
and
invalid
to
exclude.
Please
add
back
in.
There
are
several
value
stations
and
appurtenance
piping
under
the
PSE
EE
power
lines
with
corrosion
effects
from
inducted
AC
and/or
electrochemical
corrosion
which
could
result
in
massive
leak.
The
appurtenance
piping
(test
pipe
is
just
one
of
many
Pg 16 of 58
connected
to
the
Olympic
pipeline)
was
involved
in
the
Olympic
pipeline
fire
in
Newcastle.
BBB.3
pg
423/574
“Throughout the study area, the Olympic Pipelines are externally
coated and catholically protected, primarily with overlapping impressed current systems
(West, pers. comm., 2016). These systems consist of an array of metallic anodes buried in
the ground along the pipeline with a connection to a source of electric direct current
(DC) [see BBB5] to drive the protective electrochemical reaction.” DC protection for
AC driver of the PSE EE lines is a disaster waiting to happen. Please explain and detail
pipeline lifespan of this so called “protective” DC system in term of years of pipeline left
with the 115kV current lines and the EE 230kV lines.
BBB.4 The colossal lack of competent analysis of pipeline safety is also revealed by this
report. PipelineTechJoure(foundlooking$..EN15280)ptj-1-2015.pdf “Evaluation of AC
Corrosion Likelihood of Buried Pipelines Applicable to Cathodically Protected
Pipelines,” 2013 www.pipeline-journal.net/pdf/ptj-1-2015.pdf
The EE EIS nor the fraudulent PSE (DNV-GL) pipeline safety report analyze the two
parallel pipe corrosion issues, please do so. Given the EE DNV-GL pipeline safety report
is so incompetent; missing even the basics of stress corrosion and the acceleration of
further corrosion from electrochemical reaction inducted by EE 115kV and proposed
230kV lines it is not surprising the children hired by the City of Bellevue missed a
bachelor of science level effect as shown below. See Japanese paper.
Pg 17 of 58
Also include the analysis of natural gas pipelines both transmission and local distribution
lines. The local distribution lines, even if plastic and not metal pipes, will have the
dominant impact. For the technically illiterate contractors hired by the City as well as
City of Bellevue staff plastic pipes have tracing metal wires. “An electrically continuous
corrosion-resistant tracer wire (minimum AWG 14)” is required per all city codes and
has only a minor less electric-chemical corrosion effect than a 16” or 20” metal pipe
lines or Sound Transit light rail effect.
Please add this very relevant and significant analysis into the redo to the EE EIS. And do
not forget to add the analysis figure 3 below. The electrical coupling of water pipes,
metal fences, metal siding, roofing etc. Please note the author assumption of “In these cases,
pipeline and GeS are more or less parallel metallic conductors due to their similar conductive material.” Is likely not
accurate it could easily be perpendicular driven in many spot cases.
Pg 18 of 58
For the technically illiterate that produced the EE EIS and the DNV-Gl Olympic pipeline
safety report) and the so called “technical experts” reviewing please include the risk from
the coupling and resulting corrosion you will see from new Sound Transit lines
(regardless DC or AC) in areas around PSE EE. In case your technically illiterate nature
wants to dismiss it, accept for direct crossings, let me provide you with the following
figure below. PIV= Pipeline inducted voltages. Notice the induced voltage vs pipeline
distance, normally one would not have to call this out but given the staggering technical
illiteracy of the EE EIS contractors and City of Bellevue Staff, I feel compelled too do so.
The Israelis only do it out to 500m but they have very dry soil so AC inducted corrosion
issues drop off significantly.
Pg 19 of 58
BBB.5
See
2011
Japanese
paper
“STRATEGY
FOR
ELIMINATING
RISKS
OF
CORROSION
AND
OVERPROTECTION
FOR
BURIED
MODERN
PIPELINES”
attached
as
P2-‐43_Fumio
20Kajiyama.pdf
http://members.igu.org/old/IGU%20Events/igrc/igrc2011/igrc-‐2011-‐
proceedings-‐and-‐presentations/poster-‐papers-‐session-‐2/P2-‐
43_Fumio%20Kajiyama.pdf
pg
2/21
“It has been definitely shown by the occurrence of AC corrosion on a cathodically
protected pipeline that AC corrosion cannot be prevented by CP in the presence of very high AC
voltage of a pipeline.
“
and
pg
4/21
“4.1 UNDERSTANDING OF AC CORROSION
AC corrosion was not well understood for two reasons: (1) the interaction of AC and DC currents
affecting the electrochemical phenomenon of corrosion is very complicated, and (2) the
instrumentations used to measure the electric parameters in DC and AC with frequencies
between 50 and 100 Hz were not available.”
Please
detail
the
results
of
this
highly
technical
approach
for
liquid
distillates
(Jet
fuel,
aviation
gas
and
auto
gasoline)
which
have
higher
dissolved
water
than
the
levels
seen
in
natural
gas
resulting
in
higher
corrosion
and
the
expected
lifespan
reduction
to
the
Olympic
pipeline
from
the
analysis
approach.
Please
include
the
much
higher
electrochemical
induction
corrosion
results
for
the
lead
additive
in
aviation
gas.
This
could
be
seen
in
the
PIG
dat
if
only
one
pipe
was
limited
to
just
aviation
gas
transport
for
a
significant
portion
of
the
time
CCC.1
Map
&
compare
the
stress
corrosion
from
actual
measured
PIG
results
on
the
Olympic
pipeline
over
time
with
any
seismic
activity
that
has
occurred
on
or
near
or
could
be
felt
on
the
Olympic
pipeline
or
could
cause
shifting
across
crack
boundaries.
See
seismic
Only
6
fluffy
mentions
of
earthquake
in
the
main
574pg
EE
EIS,
given
this
is
such
a
likely
and
critical
event
how
is
this
justified?
Ignorance?
Earthquake
risk
going
to
230kV
from
115kV
has
to
at
least
double
the
risk
from
solely
from
the
arc
fault
puncturing
the
20”
or
16
inch
gasoline
pipeline
under
800psi.
I
know
the
EE
EIS
staff
wants
to
be
like
Edward
Bernays
and
his
student
from
afar,
Joseph
Goebbels,
(the
Army
found
every
paper
and
all
11
books
at
the
time
of
Bernays’s
in
Goebbels’
office
after
the
war)
but
I
must
insist
on
this
one
decency
from
the
EE
EIS
staff.
000.
2.
Is
there
anybody
here
from
DNV-‐GL
who
wrote
the
Pipeline
safety
report
here
to
explain?
Ask
Carol
Helland
for
sure
on
video.
00.
Do
you
feel
you
were
given
the
right
amount
of
time/funding
and
data
to
do
a
honest
accurate
and
reliable
job
doing
the
actual
work
or
reviewing
the
work
done
by
others
on
EnergizeEastside
powerline
upgrade
to
230kV
the
EIS?
0.
I
find
the
reports
generated
for
EE
in
general
and
EE
pipeline
highly
obfuscated
and
purposely
meant
to
hide
the
facts.
A
massive
fraudulent
whitewash.
0.b
If
Pipeline and Hazardous Materials Safety Administration (PHMSA) regulation
where not used for the DNV pipeline safety study what would you say to that?
Pg 20 of 58
0.c
Why
are
the
engineering
standards
not
clearly
explained
in
the
DNV-‐GL
pipeline
safety
report?
None are used. Instead DNV mostly
uses
conclusions
from
a
1986
German
investigation
or
other
deadend
or
madeup
“standard
practice”
!!!
Are
there
far
better
standards
available?
0.d
What
country
has
the
best
liquid
pipeline
safety
standards?
Why
are
USA
liquid
distillate
standards
not
being
used
or
quoted,
only
natural
gas
pipeline
safety
standards?
Regulations §49 CFR Part 195 Subpart H Corrosion Control (195.551 – 195.589)26 and §49
CFR Part 192 Subpart I Requirements for Corrosion Control (192.451 – 192.491)27?
Here
are
the
reference
for
the
rpt=
no
PHMSA
regulation
standards
How
do
European
standards
compare?
Pg 21 of 58
Why
are
the
European
standards
not
clearly
labeled
in
the
DNV
and
refer
rpts??
Why
are
the
EU
standards
not
being
used?
Not
a
single
reference
to
ISO
standards.
Q.
Who
has
the
newest
for
safety
pipeline
and
corrosion
standards?
The
EU,
USA,
Japan
other?
Q is this so called guidance foolish and dangerous or the “State of the Art”?
Pg 22 of 58
Pg402/574 “Due to concerns surrounding pipeline ruptures in 2010 (in Marshall,
Michigan, and San Bruno, California), Congress passed the Pipeline Safety, Regulatory
Certainty, and Jobs Creation Act of 2011. This law mandated a variety of new safety measures,
and directed the Pipeline and Hazardous Materials Safety Administration (PHMSA) to evaluate
concerns surrounding the pipeline ruptures and to submit a report to Congress. Based on those
findings, PHMSA is developing rule changes to 49 CFR Part 195, Hazardous Liquid Pipeline
Safety Regulations.
Are
those
rule
changes
done?
When
will
they
be
done?
Why
are
they
not
quoted?
Why
is
this
critical
information
(the
rule
changes)
left
out
of
the
DNV
Safety
report
AND
references?????
1.
(Question
for
the
574
pg
authors
as
they
wrote
it
and
split
it
up
On
pg
402/574
there
are
new
rule
coming
from
Pipeline
and
Hazardous
Materials
Safety
Administration
(PHMSA)
How
long
have
they
been
working
on
the
prosed
rules??
When
will
the
rules
be
finalized???
It
has
only
been
18
yrs.
Why
was
the
history
started
at
2010
pipleline
accidents
and
the
2002
accident
resulting
in
more
rules
pushed
down
Appendix
I=pg151/274???.
“The
two
pipeline
incidents
that
led
to
the
passage
of
the
2002
Pipeline
Safety
Improvement
Act
of
2002
and
the
current
pipeline
integrity
management
rules
are
as
follows:
Bellingham, Washington, June 10, 1999.
· Carlsbad, New Mexico, August 19, 2000. Per the National Transportation Safety Board accident report,
Do
you
find
there
is
a
lack
of
regulatory
standard
and
regulatory
dysfunction
with
regard
to
pipeline
safety
for
the
USA?
For
EU?
The
is
Act
was
2002
here we are 18
years later and still have no liquid distillate pipeline safety standards????!!!!!!
Pg 23 of 58
I
know
why.
Same
reason
we
still
have
lead
in
aviation
gas
40
years
after
it
should
have
been
taken
out.
Pg 24 of 58
Q.
How
many
of
the
below
incidences
were
in
highly
populated
areas?
Q.
What
are
the
expect
fatalities
with
the
incidents
in
unpopulated
area
had
happened
in
densely
population
areas.
Q.
Why
does
the
EE
EIS
on
show
liquid
incidents
when
in
fact
the
DNV-‐GL
pipeline
safety
study
only
uses
natural
gas
standard
which
in
themselves
are
out
of
date
not
even
10%
applied.
Please
detail
those
that
occurred
in
populated
areas.
Please
detail
the
age
of
the
pipelines
at
failed
to
those
that
did
not
fail,
a
dot
plot
similar
to
a
bathtub
curve
will
work
=
x
axis
is
age
of
pipe
y
axis
time
since
last
inspection
and
the
size
of
the
dot
is
the
size
of
spill.
Pg 25 of 58
2.
There
was
never
anybody
from
DNV-‐GL
to
explain
the
Pipeline
safety
report
at
any
of
the
EE
EIS
open
houses.
The
replacement
for
other
companies
was
clear
on
video
tape
they
had
not
read
the
DNV-‐GL
EE
EIS
Pipeline
safety
report.
Why
does
DNV
hide
it
own
report
internally
when
they
are
public
record?
Because
there
is
massive
collusion
and
fraud
in
the
fossil
fuels
industry
and
supporting
service
companies
including
all
the
contractors
the
City
of
Bellevue
has
hire
to
conduct
and
review
the
EE
EIS.
2a.
☒
Limited distribution within DNV GL after 3 years
VERY
odd
given
this
is
a
public
report
Why
would
DNV
limit
expect
to
hide
things??
2b.
Zero
stress
corrosion
cracking
discussed
in
the
DNV-‐GL
the
Pipeline
safety
report
for
EE.
Why
is
that?
See
pg
64/72
Pipeline
TechJ.
This
is
simple
malpractice
and/or
fraud
for
the
prepares
of
the
EE
EIS.
Please
include
detailed
stress
corrosion
analysis?
Why?
The
EE
soil
conditions
and
movement
are
ideal
for
creating
stress
corrosion.
There
multiple
examples!!
please
detail
all
known
going
back
20
years.
EE
EIS
contract
EMA
lame
claims
about
PSHMA
sp?
new
up
grades
has
changed
and
the
utility
industry
are
magically
inspected
by
vastly
underfunded
watch
dogs
and
the
“new
standards”
have
caught
all
issue
since
2010.
I
actually
have
the
EMAXXX
orifice
saying
this
on
video.
PSE
latest
June
19
2017
pipeline
safety
settlement
sows
this
BS
assertion
utterly
false
and
fraudulent.
Here
is
one
example
stress
corrosion.
“On
December
13,
2003
the
Williams
26-‐inch
line
ruptured
near
Toledo
Washington.
The
pipeline
company
that
supplies
most
of
Washington's
natural
gas
was
ordered
on
19
December
2003
to
all
but
shut
down
its
trunk
line
from
Canada
to
Oregon
after
federal
safety
inspectors
determined
frailties
in
the
268-‐mile
pipe
would
'likely
result
in
serious
harm
to
life,
property
and
the
environment.'
Pg 26 of 58
After
the
46-‐year-‐old
line
ruptured
twice
in
six
months,
the
federal
Office
of
Pipeline
Safety
told
Williams
Northwest
Pipeline
it
must
replace
every
section
of
line
it
hopes
to
use,
or
prove
it
is
resistant
to
stress
corrosion
cracking.
The
company's
natural-‐
gas
artery
burst
with
a
roar
on
May
1
2003
near
Lake
Tapps,
sparking
evacuations
at
a
school,
a
supermarket
and
about
40
homes.
While
such
eruptions
are
typically
caused
by
land
movement
or
other
outside
forces,
inspectors
later
identified
the
cause
as
stress
corrosion
cracking.
The
line
had
passed
inspection
within
the
previous
year.”
See
http://corrosion-‐doctors.org/Pipeline/Williams-‐
explosion.htm
2b2.
Please
detail
what
the
current
US
federal
and
WA
state
stress
corrosion
regulations
for
liquid
fossil
fuel
pipe
lines
before
and
14
years
after
the
above
2003
WA
fossil
fuel
pipeline
explosion.
See
the
below
comment
in
bold
of
the
federal
regulator
in
2004
acting
like
they
just
discovered
gravity
and
it
is
a
new.
Please
detail
the
differences
for
various
countries
(USA,
UK
EU,
Norway,
Japan,
Saudia
Arbia)
in
pipeline
stress
corrosion
regulations.
Please
contrast
this
with
design
knowledge
and
standards
of
the
US
Navy
Army
and
Air
Force
military
fuel
depots
and
refueling
ships
and
aircraft
for
stress
corrosion
and
well
as
the
same
in
other
countries.
From 2004 ref above: “The same type of cracking caused another section of the Williams line to leak in
1999 and fail during tests in 1992. In 1994, a lateral line on the same system near Oregon City, Ore., failed
22 times during tests. After repairs were made to the line near Lake Tapps in May, inspectors ordered the
company to reduce the line's gas pressure 20 percent to 632 pounds per square inch. Following a similar
break on an oil pipeline in Tucson, Arizona that sprayed 30,000 gallons of diesel fuel onto homes, federal
inspectors issued a formal alert to pipeline operators about stress corrosion cracking.
Pg 27 of 58
Inspectors typically examine lines by running water through them at high pressure. But such hydrostatic
testing doesn't guarantee there's no problem there and can't reveal stress corrosion cracks. Until recently,
companies weren't required to do the complex in-line inspections that might catch the problem.
"We have no actual regulation saying that you need to address (stress corrosion cracking) in your
pipelines," said Hill, with the federal safety office. "Basically, it's a new phenomenon, and we're studying
it." [THIS comment in bold is either fraud or
purposeful incompetence, the US Navy has been
dealing with stress corrosion for over 100 years
particularly in piping. Yet another example for the
massive fraud which is the US fossil fuels industry
and its corruption of the government regulators. For
the EE EIS please detail the results of that “studying”
has been 13 years later!!!!!!!!! And the inspection
tools to “might catch” the problem]
Even today, state and federal regulators acknowledge stress corrosion cracking must be considered when
evaluating a line's integrity, but in-line testing is required only where pipelines run through populated areas.
Companies can get around even those tests, some said.
"The problem, particularly in the gas industry, is they aren't built for this kind of testing, so the law gives
them an out," said Kim West, senior pipeline-safety engineer for the state. [!@#$%^&
unbelievable fraud in our state & federal regulations,
not civil service fault criminal fossil fuels industry
and criminal politicians]
Please detail the level of maturity of Federal and
State regulations for this industry and the level of
change those regulations have seen after 80 years say
circa 1995 and the “massive” or lack there of, level of
changes since then, every ten years say 2005, 2015
and those pending. Compare and contract as you did
with societal risk but for these Fed and state
regulation please include Texas in the analysis. And
detail what laws are in effect to give the utilities
Pg 28 of 58
industries a “legal out” as the WA UTC pipeline
safety engineer denoted.
What
are
the
lack
of
funding
and
impact
of
June
19
2017
PSE
for
the
real
societal
risk
calculated
in
the
EE
EIS?
“As
for
that
settlement
money,
none
of
it
goes
to
any
of
the
victims
affected
by
the
blast.
Instead,
it
will
go
into
a
fund
to
promote
pipeline
regulation
and
safety
projects.”
What
is
the
current
risk
impact
of
“lack
of
funds
to
promote
pipeline
safety
“
in
WA
effect
PSE’s
EE
project?
What
are
the
details
of
the
coal
tar
coating
used
on
the
OPLs
in
term
of
stress
corrosion
susceptibility.
Also
what
are
the
AC
inducted
deterioration
of
the
coal
tar
coatings
and
other
deterioration
including
microbial.
What
is
the
expect
lifetime
left
in
the
coal
tar
coating?
Pg 29 of 58
2c.
What
buried
coupon
testing
is
for
pipeline
corrosion
get
done
for
Olympic
pipeline.
Please
detail
including
that
done
for
stress
corrosion.
2d.
CofB
please
force
the
criminally
convicted
BP
to
release
ALL
Olympic
pipeline
inspection
records
and
include
in
the
EE
EIS
and
for
the
EE
EIS
to
access
remaining
pipeline
lifetime
left
with
current
115
kV
lines
and
detailed
analysis
showing
pipeline(S)
reduction
with
the
230kV.
How
does
stress
corrosion
different
in
hilly
pipeline
area
vs
flatland
vs
known
or
suspected
fault
lines,
particularly
those
the
PSE
EE
18
miles
of
pipeline
in
densely
populated
areas?
Please
note
significant
AC
coupling
as
far
away
as
2km.
Given
the
complete
lack
of
competent
contractors
working
on
EE
EIS
[given
CoB
ignored
its
own
electrical
reliability
report,
to
hire
technical
staff
to
help
hire
outside
staff,]
here
is
what
a
fact
based
and
almost
complete
good
engineering
approach
looks
like
below
the
picture
of
what
happen
when
you
do
not.
The
Exponent
report
is
a
surprising
amount
of
honesty
from
the
expert
at
Exponent
well
known
for
it
fake
science
and
is
like
duely
to
the
fact
he
was
well
into
retirement
want
to
atone
for
his
sins
or
just
a
partime
guy
who
didn’t
get
the
memo
to
lie.
www.corrosionclinic.com/corrosion_courses/External%20Pipeline%20Integrity%2
0Assessment%20and%20Composite%20Repairs.htm
Pg 30 of 58
Pg 31 of 58
Pg 32 of 58
regular
outside
pipe
surface
corrosion
and
inside
surface
of
pipe
corrosion
chemically
or
electrically
inducted
is
above
in
figure
6.
Below
in
is
internal
pipe
corrosion
resulting
from
stress
corrosion.
See
pg
xx
of
Pipeline
Tech
Journal.
Please
detail
the
resolution
of
BP’s
“
high
resolution
deformation
and
high
resolution
magnetic
flux
leakage
tool
in
April
2014.”
And
compare
to
state
of
the
art
of
PIG
inspection
tools.
Why
is
the
next
inspect
5
years
later?
What
regulation
drive
that?
Pg 33 of 58
Is
that
regulation(s)
current
or
under
review,
How
doe
it
compare
to
UK
and
ISO
standards?
Please
do
the
risk
analysis
of
the
proposed
230kV
power
line
and
the
increased
risk
resulting
from
stress
corrosion
combining
with
AC
inducted
currents.
To
do
this
risk
the
CoB
will
need
to
require
the
PIG
inspection
data
from
the
Olympic
pipeline
Company.
Also
include
soil
pH
and
resistivity
at
the
pipe
depth
not
just
the
average
pipe
depth
in
both
SCC
(stress
corrosion
cracking)
What
are
details
the
number
of
pipe
holidays
(
nice
way
for
the
industry
to
sugar
coat
&
hide
facts)
holidays
are
breaks/hole
in
the
pipes
exterior
coating
which
for
the
Olympic
pipeline
is
coal
tar.
2d.(continued)
Here
is
what
trained
technical
experts
say
about
coal
tar
and
stress
corrosion.
“• In addition to an appropriate coating failure, the local soil, temperature, water
availability, and bacterial activity have a critical impact on SCC susceptibility. Coating types such as coal
tar, asphalt and polyethylene tapes have demonstrated susceptibility to SCC. Fusion bonded epoxy hasn't
shown susceptibility to SCC.
• Loading is the next most important parameter on SCC. Cyclic loading is considered a very important
factor; or the crack tip strain rate defines the extent of corrosion or hydrogen ingress into the material.
There has been no systematic effect of yield strength on SCC susceptibility. Certain types of ERW pipe have
been found to be systematically susceptible to SCC. Non-metallic inclusions have also had limited
correlation to SCC initiation.”
Here,
the
above
non
EE
EIS
authors
are
correct
that
cyclical
loading
is
a
very
important
fact,
but
long
term
static
stress
from
different
ground
shifting
is
enough
such
a
pipe
crossing
as
earth
quake
fault
line
or
hillside
slippage
or
alluvial
fan
movement
including
those
up
slope
or
down
slope
from
the
pipeline.
What
are
the
current
static
mechanical
stress
on
the
pipes
and
how
will
new
towers
effect
that
stress.
How
is
will
the
changes
in
freeze/thaw
cycles
due
to
the
new
towers
effect
pipe
stress/stress
corrosion?
New
towers
will
be
as
close
as
13
feet
to
the
pipes.
Q4.2.4
pg
35/66(INGAA)
How
does
Coating
Resistance
break
down
voltage
change
with
time
and
degradation?
What
is
the
increase
arc
fault
and
arc
fault
puncture
of
the
pipe
with
230kV
lines
vs
115kV.
Pg 34 of 58
Earthquake
or
$20
terrorist
attack.
What
is
the
arc
fault
risk
of
the
230
kV
lines
to
some
who
pound
a
6
foot
½
inch
steel
metal
agriculture
rod
to
say
support
a
tree
nearby
or
a
terrorist
doing
so
right
on
the
pipeline.
2e.
What
is
the
level
of
over
protection
currently
of
BP
Olympic
pipeline’s
DC
catholic
protection
system
verses
the
AC
inducted
currents
from
the
115kV
power
lines
currently
and
those
of
the
proposed
230kV
lines?
See
part
b
of
figure
1
below.
How
will
this
overprotect
change
with
230kV
lines
and
it
impact
on
the
corrosion
and
lifetime
of
the
pipe
and
predictability
of
failure
of
the
pipe?
Pg 35 of 58
3.
Why
is
there
zero
mention
of
Department
of
Transportation
(DOT)
Pipeline
and
Hazardous
Materials
Safety
Administration
(PHMSA)
in
the
DNV-‐GL
pipeline
safety
report?
No
one
word
of
either
Nor
49 CFR Part 195
Nor PHMSA is developing rule changes to 49 CFR Part 195.
In
fact,
contrary
to
what
I
have
the
CoB
contractors
on
video
tape
saying
that
the
DNV-‐GL
pipeline
safety
report
uses
PHMSA
regulations
when
in
fact
does
not!
In
fact
PHMSA
are
still
not
finalized!
If
so
please
denote
In
fact
the
DNV-‐GL
pipeline
safety
report
only
uses
reference
material
as
standards
that
the
authors
of
the
DNV-‐
GL
pipeline
safety
report
themselves
wrote,
the
2015
INGAA
report
“Criteria
for
Pipelines
Co-‐Existing
with
Electric
Power
Lines
Pg 36 of 58
4.
The
only
reference
to
criteria/recommendation
corrosion
is
a
2015
INGAA
report
“Criteria
for
Pipelines
Co-‐Existing
with
Electric
Power
Lines,”
The
INGAA
Foundation
2015-‐04
(zero
standards
from
the
PHMSA
in
force)
Please
detail
fossil
fuel
industry
obstruction
of
regulation
and
limiting
to
fines
including
service
industries
such
as
DVN-‐GL
and
the
current
contractor
firm
working
on
this
report.
5.
What
are
the
top
five
oldest
jet
fuel
pipelines
paralleling
high
power
AC
lines
for
more
than
10
miles.
Is
there
a
reason
the
Case
1
or
2
in
DNV
report
just
went
0.95
miles
(5000ft)
the
EE/pipeline
goes
400
miles
(~62,000
ft
in
EE
study
area)
under
high
voltage/current.
*
from
http://www.ingaa.org/about.aspx
The
Interstate
Natural
Gas
Association
of
America
(INGAA)
is
a
trade
organization
that
advocates
regulatory
and
legislative
positions
of
importance
to
the
natural
gas
pipeline
industry
in
North
America.
• Ist
it
appropriate
to
quote
natural
gas
corrosion
criteria
for
liquid
distillate
criteria?
pg17/66(INGAA)
“In 1986, a corrosion failure on a high-pressure gas
pipeline in Germany was attributed to AC corrosion.
AC-induced corrosion does not occur at AC densities less than 20 A/m2 (1.9 A/ft2).
*
pg
58/66(INGAA)
While not a Standard Practice document, NACE published “AC Corrosion
State-of-the-Art: Corrosion Rate, Mechanism, and Mitigation Requirements”1 in 2010,
providing guidance for evaluating AC current density, and providing recommended limits as
discussed in Section 3.3.1.1.,
ref
15=
The
DVN
auther
reference
this
INGAA
report
which
they
themselves
also
wrote.
Why
did
they
reference
it?
Why
does
the
DN-‐GL
safety
report
not
fully
detail
the
crossing
angle
criteria?
What
exactly
are
the
AC
inducted
effects
for
a
zero
cross
angle?
The
DN-‐GL
safety
report
only
mentions
it
twice
in
entire
report
See
2nd
yellow
highlighting.
Below
is
the
referenced
work
of
the
DNV-‐Gl
authors
which
they
also
wrote=the
INGAAC
report
of
2015.
Why
are
there
not
references
and
who
validated
this
criteria?
Pg 37 of 58
Who
vadidated
DNV-‐GL
model?
How
accurate
is
it?
And
if
is
is
not
Also
what
are
the
corrosion
effects
Why
are
the
last
0
to
15
degrees
crossing
angles
left
off
that
is
the
case
the
EE
EIS
is
analyzing?
Would
you
leave
off
the
last
15degrees.
How
to
charts
like
this
compare
to
other
governing
regulation
and
to
other
bodies
of
work?
Who
says
NACE’s
15V
criterion
is
the
what
to
use?
The
authors
themselves
admit
15VAC
is
not
to
be
used
for
corrosion
only
personel
safty,
that
is
getting
their
butts
electrocuted.
The
PSE/OPL
crossing
angle
is
zero
in
most
cases
how
could
DNV-‐PL
analysis
be
vaild
for
even
the
Who
is
the
governing
body
that
bless
the
20Amp/m2
criterion
the
DNV
authors
use?
Here
is
that
31
year
old
(1986)
German
investigator
20Amp/m2
when
the
EU
standard
is
ISO
standard
ISO
15589-‐1
is
3
A/m2
or
less
“prescribes
for
the
AC
corrosion
risk
and
CP
as
follows:
If
the
a.c.current
density
on
a
100
mm2
bare
Pg 38 of 58
surface
(e.g.
an
external
test
probe)
is
higher
than
3
A/m2
(or
less,
in
certain
conditions),
there
is
a
high
risk
of
corrosion.
“
Pg 39 of 58
Why
no
earthquake
risks
analyzed
just
mention
the
word
6
times
all
fluffy.
Why
is
EDM
Services
is
the
reference
why
not
DOT
or
PHMSA?
How
is
EDM
Service
anymore
relevant
reference
than
quoting
Donald
Duck?
What
is
the
base
data
source
and
what
id
the
base
data?
This
is
same
DNV
before
being
repurposed
for
INGAA=DNV/Puget
Sound
Energy
ref
Pg 40 of 58
Pg 41 of 58
ISO
standard
ISO
15589-‐1(2003=Old
current
is
2015)
is
3
A/m2
or
less
“prescribes
for
the
AC
corrosion
risk
Pg 42 of 58
Pg 43 of 58
Q=
pg
35/66(INGAA)
EE
does
not
have
100ft
horizontal
separation
we
have
zero
to
25
feet
Nor
do
we
go
just
1
mile
(5000ft)
we
go
hundreds
of
miles.
pg
35/66(INGAA)
DNV GL created a computer model simulating a single pipeline, parallel to a
single circuit vertical transmission line for 5,000 feet at a horizontal separation distance of
100 feet.” “ The model used a uniform soil resistivity of 10,000 ohms-cm.” Se below
Pg 44 of 58
Pg 45 of 58
That
is
the
temperature
of
a
static
electricity
spark?
Ellingham_diagrams=An
Ellingham
diagram
is
a
graph
showing
the
temperature
dependence
of
the
stability
for
compounds.
This
analysis
is
usually
used
to
evaluate
the
ease
of
reduction
of
metal
oxides
and
sulfides.
These
diagrams
were
first
constructed
by
Harold
Ellingham
in
1944.[1]
In
metallurgy,
the
Ellingham
diagram
is
used
to
predict
the
equilibrium
temperature
between
a
metal,
its
oxide,
and
oxygen
Pg 46 of 58
—
and
by
extension,
reactions
of
a
metal
with
sulfur,
nitrogen,
and
other
non-‐
metals.
or
Pg 47 of 58
2015
book
Pg 48 of 58
What
is
Model
Node
number?
Why
is
the
1986
German
(not
a
standard)
investigation
conclusion
number
of
20Amp/m2
used
not
at
PHMSA
standard
or
a
ISO
standard?
Pg 49 of 58
Pg 50 of 58
pg
48/66(INGAA)
In
the
Defense
Department
when
we
make
charts
like
this
with
no
references
we
call
this
chart
“winging
it
and
ass
wild
guess
Do
either
of
the
below
case
match
what
EE
EIS
situation
18
miles
of
collocated?
See
scrn
capture
below
Pg 51 of 58
Why
do
the
authors
of
the
DVN
report
which
they
reference
say
in
their
INGAAC
report
that
it
is
a
requirement
to
take
soil
resistivity
readings
at
multiple
depths
see
below
scree
shot.
Yet
in
their
DNV
report
at
the
average
pipe
depth
but
not
at
the
pipe
depth
at
the
32
locations
taken.
Pg 52 of 58
Here
is
what
the
DNV-‐GL
EE
report
said.
It
below
at
multiple
depths?
The
Israeli
pipeline
safety
methodology
requires
“Perform a soil resistivity test every
500m along the pipeline route. Where a change of more than 10Ω/m is identified between two
measurements, the distance between test locations should be reduced until sufficient resolution is
provided to determine the exact extent of the low resistivity area. The depth for which the
Pg 53 of 58
measurements are taken shall be the same depth as the pipeline.”
http://energy.gov.il/Subjects/NG/Documents/Directive/34537-
ACInducedCorrosionDirectiveRev.pdf See
screen
shot
below. Given
the
low
soil
resistivity
is
the
critical
safety
parameter
why
is
not
carefully
handled?
Compare
to
the
pg
48/66(INGAA)
report
and
that
to
same
slightly
less
washed
out
table
A1.
There
they
write
Soil Resistivity - ρ (ohm-cm) ρ < 2,500
the
is
VERY
HIGH
Relative Severity of HVAC Corrosion, see Table 5 below.
Compare
this
to
above
to
table
5
above
to
table
A1
below.
There
are
multiple
readings
below
2,500 ohm-cm mean very high HVAC Corrossion dozens below 10,000.
Why
are
the
readings
not
denoted
if
the
are
wet
or
dry
soil?
Why
is
the
Isreali
method
not
used
to
determined
the
full
extent
of
the
low
resistivity?
Isreali
method
=“Where a change of more than 10Ω/m is identified between two measurements, the distance
between test locations should be reduced until sufficient resolution is provided to determine the
exact extent of the low resistivity area”
The Israeli regulation are designed to get the low areas of soil resistivity fully identified
and they are in a very dry soil conditions and they were concerned. Why are these rules
not followed give corrosion risk is much higher? Are DVN paid to looked the other way
by PSE? IS the CofB’s technical contractors paid to look the other way or incompetent?
Pg 54 of 58
Why
are
there
no
USA
standards
for
pipeline
safety
levels
for
soil
resistivity,
soil
pH...long
list
of
other
parameters??
It
is
not
because
the
USA
Oil
industry
has
prevented
those
standards
from
being
created?
The
EN
15280:2013,
is
a
British
Standard.
See
scrn
shot
a
bit
below
Did the DNV authors forget that for their low reading was 66
Why
do
the
above
table
mismatch
for
minimum
values
with
this
on
pg
39
/49
of
the
same
DNV
doc
“the local
soil resistivity ranged from 66 ohm-m to 3,256 ohm-m. Considering the local soil resistivity
along the collocation, the resulting arcing distances range from 4 ft to 13 ft at these pole
locations.”
Pg 55 of 58
By
this
gage
the
risk
is
only
high
if
soil
is
wet??
Really
please
detail
corrosion
risks
for
dry
soild
and
those
for
wet.
As
for
EN
15280
the
National
Building
Specification
(owned
by
the
Royal
Institute
of
British
Architects)
says
to
use
with
caution.
Please
detail
exactly
the
nature
of
the
caution
when
not
in
the
Construction
Information
Service.
See
scrn
shots
below.
Pg 56 of 58
Wow
actual
measurements
not
the
averaged
so
risk
is
very
high.
Please
provide
pipeline
inspection
measurements
for
this
low
areas.
What
is
the
lifetime
left
in
the
pipe
for
these
areas
and
that
expect
when
increased
to
230kV.
Pg 57 of 58
Pg 58 of 58