Bill Huston Podcast: July 2021

There's very big problem with adding compression to old pipelines.

(Iroquois was built 36 years ago)

The MAOP (maximum allowable operating pressure) of a pipeline is determined by several factors called Barlow's Formula.

https://en.wikipedia.org/wiki/Barlow%27s_formula

You will see that one such factor is the pipe thickness. Yet we know that over time a pipeline thickness will degrade & thin over time due to corrosion. This means that over time the MAOP should be adjusted DOWN!

However this is not what we see! Due to the demands of market and the greed of pipeline companies they want to move more product over time so they tend to try to INCREASE pressure.

Pipelines operate at a pressure gradient, generally the highest at the outlet of a compressor in the lowest at the inlet of the next compressor. However this is modulated by things like gravity, & the height of the pipe.

The outlet of compressor stations almost always run at very close to the MAOP. So how can they increase pressure without also increasing the MAOP?

The answer is that FERC/PHMSA allow older pipelines to run at INCREASED MAOP through a program called "Alternative MAOP".

This is absolutely insane because it runs counter to physics. These compression only solutions to increasing pipeline capacity only add stresses to these aging pipelines and increase the chances of a pipeline failure, and according to my research, these spontaneous failures most often happen within 4 MI downstream of the outlet of a compressor.

I hope you all will take some time to write a comment opposing this expansion of the Iroquois pipeline, which poses a real threat to our Hudson valley neighbors.

---------- Forwarded message ---------
From: 'Mary Finneran' via NYGCG - New York Gas Coordination Group
Date: Tue, Jul 27, 2021, 8:06 AM
Subject: [NYGCG] Tell FERC: "No" to the Berkshire Hathaway owned Iroquois EXC by August 9

Hi Allies in fighting climate catastrophe, following is a blast from the Sierra Club Atlantic Chapter which asks for comments to FERC regarding their draft Environmental Impact Statement (EIS) on the Iroquois Expansion by Compression Project (IEXC), the directions given to commenting are simple, albeit two step.

A good synopsis of the IEXC is in the Sierra Club email (thanks Atlantic Chapter). Quick additional points:

1. the Iroquois Pipeline moniker is a heinous insult to the Haudenosaunee people and has been for 30 plus years.

2. Berkshire Hathaway now owns the pipeline system, which makes this project a true natural gas mega corporation project.

3. This project is one of the Plan B options National Grid (and Con Ed) proposed when Cuomo demanded the gas companies find ways to provide heat when the Williams Pipeline was shut down. Other intolerable plans include the NBK pipeline, LNG and CNG expansions, including more bomb trucks, (exportations???) etc. WE demand sustainable options, "they" would like all Plan B.

The Sierra Club has provided a great sample comment, but attached you will find some info from the EIS, IEXC, and quotes of others' comments for your inspiration to help enhance your comments. Please look it over, and please comment, more than once if you like! In solidarity for the planet and 7 generations, Mary

Dear Mary,

In this summer of fires and floods, climate change is ravaging the earth and the call to action has become all the more urgent. Two years ago, NYS established nation-leading laws to make New York carbon neutral within 30 years – ending our need and dependence on dirty fossil fuels and their climate killing emissions. But despite these enforceable laws, fossil fuel companies continue press New York state to build new fracked gas pipelines, compressor stations and power plants.

Case Example: The Iroquois Expansion by Compression Project (ExC) proposed by National Grid (and Con Ed) seeks to pump more fracked gas into NYC after Governor Cuomo demanded that utility companies find alternative ways to provide heat to new customers after blocking the Williams Pipeline. In compliance with the Climate Leadership and Community Protection Act, utility action requires the implementation of building efficiency and geothermal heating and cooling programs, not an increase of the dirty fuels we are supposed to phase out.

FERC is seeking comments on its Environmental Impact Statement for the ExC project. Comments are due by August 9. The Impact Statement will be considered in the decision-making process to determine whether the gas expansion project moves forward. FERC's own analysis says that the project would negatively contribute to climate change.

Instructions to send a message

Go to FERC's e-Comment site, provide your information and click "Authorize." You will receive an email with a link you can click to submit your comment. Make sure to enter the Docket Number CP20-48-000 in the docket number field, then type out your comment. Here's a sample comment:

"I am opposed to the Iroquois Expansion by Compression Project (ExC) as it would violate New York's climate laws and exacerbate climate change. FERC's own Environmental Impact Statement in Docket Number CP20-48-000 says the ExC project to expand four existing gas compressor stations in Connecticut and New York will increase greenhouse gases in the atmosphere and will contribute to climate change. Climate change is a grave emergency that threatens every aspect of our lives. Compressor stations also endanger the health and safety of communities; expanding the capacity of these stations increases those risks. I urge FERC to respond by rejecting this project. The risks to people and the planet are too great."

The Iroquois ExC would significantly increase the amount of natural gas being pushed through it's 30-year-old pipeline from the Compressor station in Athens NY, to the compressor station in Dover, NY (home of Cricket Valley Power Plant), through to several Connecticut compressor stations and back to NYS to cross the AIM pipeline on its way to NYC. They will accomplish this by adding new turbines at the compressor stations, increasing the pressure in their aging pipeline – which will deliver more gas but will also significantly increase greenhouse gases and toxic air emissions.

While we are specifically concerned with the impacts upon this pipeline expansion it is difficult to ignore the impacts that fracking continues to inflict upon climate and the people of Pennsylvania. The ExC project would serve to further this enduring environmental injustice by continuing to frack the water, air and rural landscapes of the keystone state. This expansion has to stop.

Thank you for taking action to uphold NY's climate laws

Sincerely,
Kate Bartholomew
Chapter Chair,
Sierra Club Atlantic Chapter

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