WBI ENERGY TRANSMISSION, INC. Spiritwood Compressor Station Project. Resource Report 11 Reliability and Safety DRAFT

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1 WBI ENERGY TRANSMISSION, INC. Spiritwood Compressor Station Project Resource Report 11 Reliability and Safety DRAFT January 2015

2 SPIRITWOOD COMPRESSOR STATION PROJECT Resource Report 11 Reliability and Safety Minimum Filing Requirements for Environmental Reports: Describe how the project facilities would be designed, constructed, operated, and maintained to minimize potential hazard to the public from the failure of project components as a result of accidents or natural catastrophes 18 CFR (m). Addressed in: Sections 11.1 and 11.2

3 SPIRITWOOD COMPRESSOR STATION PROJECT WBI Energy Transmission, Inc. Resource Report 11 TABLE OF CONTENTS 11.0 RESOURCE REPORT 11 RELIABILITY AND SAFETY DESCRIPTION OF SAFETY MEASURES Design Specifications Compressor Station Specifications MEASURES TO PROTECT THE PUBLIC Restricted Access at Compressor Station Location Odorant Corrosion Protection System Monitoring Equipment Procedures for Operations, Maintenance, and Emergency Response Field Patrols/Leak Detection Surveys Liaison Procedures with Local Authorities Emergency Plan Emergency Shut-down System Draft 11-i January 2015

4 SPIRITWOOD COMPRESSOR STATION PROJECT WBI Energy Transmission, Inc RESOURCE REPORT 11 RELIABILITY AND SAFETY Resource Report 11 provides a discussion of the reliability and safety aspects of WBI Energy Transmission, Inc. s (WBI Transmission) Spiritwood Compressor Station Project (Project). WBI Transmission will maintain and operate the Project facilities pursuant to company policies and procedures as well as U.S. Department of Transportation (DOT) Minimum Federal Safety Standards specified at 49 CFR Part 192 (Part 192). Section 11.1 describes the proposed compressor station facilities and the safety measures and applicable regulations. Section 11.2 identifies specific measures to protect the public. Resource Report 1 provides a detailed Project description DESCRIPTION OF SAFETY MEASURES Design Specifications Under the Pipeline Safety Act (49 USC et seq.), the DOT is authorized to create and enforce pipeline safety standards. The safety standards for natural gas pipelines were promulgated by the DOT via regulations in Part 192, Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards. The regulations are intended to ensure adequate protection for the public. Part 192 defines minimum safety standards as: materials selection; design of pipe and pipeline components; welding and joining components; construction; corrosion control; testing; inspection; operations; maintenance; personnel qualifications; and pipeline integrity management. The Project facilities will be designed, constructed, operated, and maintained in accordance with Part 192. The following information addresses how WBI Transmission proposes to design, operate, and maintain the Project in accordance with DOT requirements to ensure safe and reliable operation, consistent with WBI Transmission s existing facilities. Draft 11-1 January 2015

5 Part 192 defines area classifications, based on population density in the vicinity of a pipeline and specifies more rigorous safety requirements for facilities in populated areas. The class location unit is an area that extends 220 yards on either side of the centerline of any continuous 1-mile length of pipeline. The four area classifications are defined below: Class 1 location with 10 or fewer buildings intended for human occupancy; Class 2 location with more than 10 but less than 46 buildings intended for human occupancy; Class 3 location with 46 or more buildings intended for human occupancy or where the pipeline lies within 100 yards of any building or small, well-defined outside area occupied by more than 20 or more people during normal use; and Class 4 location where buildings with four or more stories aboveground are prevalent. Pipeline facilities must be designed, tested, and operated in accordance with Class Location specifications, which include higher standards for more populated areas. Pipe wall thickness and pipeline design pressures, hydrostatic test pressures, maximum allowable operating pressure (MAOP), inspection and testing of welds, and frequency of pipeline patrols and leak surveys must also conform to higher standards in more populated areas. The proposed compressor station will fall under a Class 1 designation. The DOT has promulgated a rule for Pipeline Integrity Management in High Consequence Areas (HCAs). HCAs are defined as areas where an accident could do considerable harm to people and their property. The regulation requires that a facility-specific integrity management program be developed to document procedures under which pipeline integrity will be monitored and maintained for those areas where the pipeline traverses lands or facilities that are considered HCAs (Part 192, Subpart O). WBI Transmission has developed an Integrity Management Program to further manage the safety of the facilities. The portion of WBI Transmission s existing pipeline where the Project will be located is not considered an HCA Compressor Station Specifications The Spiritwood Compressor Station will be designed and constructed to meet or exceed the safety standards for compressor stations established by the DOT in Part 192. The piping system at the station will utilize high strength steel meeting modern standards. Additionally, the existing WBI Transmission pipeline is designed to safely handle the additional gas volumes that would be transported through the system by the new compressor station. The compressor unit will be a centrifugal compressor driven by an electric turbine. The proposed compressor will be equipped with a full range of automatic emergency detection and shut-down systems. Station and unit control computers will monitor the essential functions of the compressor and associated facilities, and will trigger an appropriate sequence of remedial actions if an upset condition is detected. If the compressor station computers detect an upset condition, appropriate action within the station controls will be automatically initiated. The station will have a hazardous gas and fire detection/alarm system and an emergency shutdown system. These safety and emergency systems will be monitored 24 hours a day by the Draft 11-2 January 2015

6 on-site control systems. WBI Transmission s gas control center will also remotely monitor the facility on a continuous basis (i.e., 24 hours per day, 365 days a year) and will immediately dispatch local personnel to the site should any safety related alarm be triggered. Standard fire protection, first aid, and safety equipment will be maintained at the compressor station, and station maintenance personnel responsible for the station will be trained in proper equipment use and in first aid. The fire-fighting equipment that will be maintained on-site includes dry chemical fire extinguishers. WBI Transmission will also coordinate with local emergency response services concerning the equipment at the station MEASURES TO PROTECT THE PUBLIC WBI Transmission maintains operating policies and procedures that adhere to DOT safety requirements. These policies and procedures are periodically reviewed by the DOT and all operating personnel are thoroughly trained to perform their activities in accordance with these policies and procedures. These policies provide specific directions in inspection, testing, operation, preventive maintenance, repair, and vigilant patrols of facilities, as well as procedures to be followed in the event of an emergency. Periodic training sessions and review of operating and emergency procedures are conducted for employees. This training includes: safe operation of pipeline valves, equipment, and facilities (including meter stations and compressor stations); hazardous material handling procedures; fire fighting school; public liaison programs; and general operating procedures. The Project facilities will be operated and maintained in accordance with these procedures Restricted Access at Compressor Station Location The proposed compressor station site will be securely fenced to prevent unauthorized access. The compressor station facilities will also include intrusion detection alarm systems Odorant WBI Transmission will add odorant to the gas downstream of the custody transfer point. Odorized gas will pass through the compressor station for discharge to WBI Transmission s existing system which also carries odorized gas Corrosion Protection Part 192, Subpart I (Requirements for Corrosion Control) prescribes minimum requirements for the protection of metallic pipelines from external, internal, and atmospheric corrosion. These requirements will be met by externally coating the buried pipeline with a fusion bonded epoxy coating system, which has an outstanding record for preventing external corrosion. The effectiveness of this coating will be augmented by a cathodic protection system. Aboveground piping will be coated with a paint system that protects against atmospheric corrosion. Internal corrosion is not a concern based on the fact that transportation quality natural gas (i.e., relatively free of water, and containing low concentrations of hydrogen sulfide, carbon dioxide, and oxygen) is being transported. Coating and cathodic protection are an integral part of ensuring the structural integrity of WBI Transmission s transmission system in North Dakota. Cathodic protection prevents corrosion of the pipeline facilities by providing direct current (DC) Electrical current flow to the pipeline. This offsets the natural soil or groundwater corrosion potential that can degrade the integrity of the pipe. The cathodic protection system is inspected at regular intervals to ensure Draft 11-3 January 2015

7 proper operating conditions consistent with DOT requirements for corrosion control and mitigation System Monitoring Equipment The proposed Project will be incorporated into WBI Transmission s extensive Supervisory, Control, and Data Acquisition System (SCADA) located in its Gas Control Center. The Gas Control Center is located in Bismarck and is staffed 24 hours a day, 365 days a year. Gas controllers use SCADA to monitor and operate the pipeline system, which includes a wide range of activities such as monitoring of gas pressures and flows along the pipeline and operation of system valves along the pipeline. Data acquisition occurs at many locations along the Sheyenne Sub-system such as meter stations and compressor stations. This data is transmitted to the Gas Control Center through SCADA. If system parameters fall outside a predetermined range, an alarm is activated at the Gas Control Center and corrective action is taken by the gas controller as needed. Local WBI Transmission personnel will be dispatched in response to these alarms if intervention is required outside of the Gas Control Center Procedures for Operations, Maintenance, and Emergency Response WBI Transmission s operating policies are defined in its Operation and Maintenance (O&M) manual, Incident Management Plan (IMP), and site-specific Emergency Plans, which are all readily available to all operations employees. The manual and plans provide directions in the day-to-day operation and preventive maintenance of the transmission system, as well as procedures to be followed in the event of an incident or natural catastrophe. A site-specific Emergency Plan will be developed for the proposed compressor station. WBI Transmission s O&M Manual, IMP, and site-specific Emergency Plans are implemented according to a defined schedule, revised as necessary, and reviewed regularly by operations employees. These include the safe operation and maintenance of mainline block valves, meter stations, and compressor stations, and presentation of public awareness programs and operating procedures. Periodic reviews of these procedures provide for the latest pipeline technology, industry experience, Federal regulations, and risk management practices to be incorporated into WBI Transmission s procedures Field Patrols/Leak Detection Surveys WBI Transmission will conduct periodic instrumented leak surveys at the Project site. The site-specific Emergency Plan will discuss how leaks will be identified and addressed. WBI Transmission is a member of One Call and related pre-excavation notification organizations in the states in which it operates, including North Dakota. Through One Call, contractors provide notification of proposed excavation to a central agency, which in turn notifies the pipeline operator of the excavation locations. Should WBI Transmission s facilities be located in the area of a proposed contractor activity, a representative will be dispatched to mark out the area, consult with the excavator as needed, and witness the excavation as necessary to prevent damage to the facilities. Draft 11-4 January 2015

8 Liaison Procedures with Local Authorities Liaison with public authorities and local utilities is maintained at WBI Transmission s facilities. The site-specific Emergency Plans contain a list of contacts to be notified in case of emergency. Key components of the liaison program consist of: periodic visits with emergency agencies to inform them of the location and nature of WBI Transmission s facilities and to coordinate emergency response in the event of an incident; special information meetings and training at the invitation of WBI Transmission; and circulation of literature listing emergency telephone numbers and other pertinent data. WBI Transmission will continue to coordinate with local emergency responders before and after the proposed compressor station is operational. Yearly training updates will be held for local emergency responders Emergency Plan Under Part 192, each pipeline operator must establish an emergency plan that provides written procedures to minimize the hazards from a gas pipeline emergency. As discussed above, WBI Transmission will develop a site-specific Emergency Plan for the new Spiritwood Compressor Station facilities before the compressor station becomes operational. Key elements of this plan include procedures for: receiving, identifying, and classifying emergency events (i.e., gas leakage, fires, explosions, and natural disasters); establishing and maintaining communications with local fire, police, and public officials, and coordinating emergency response; maintaining access to the facilities and making personnel, equipment, tools, and materials available at the scene of an emergency; protecting people first and then property, and making both safe from actual or potential hazards; and emergency shut-down of the system and the safe restoration of service. WBI Transmission maintains a liaison with appropriate fire, police, and public officials to learn the resources and responsibilities of each organization that may respond to a gas pipeline emergency, and coordinate mutual assistance in responding to emergencies. Police and fire departments in the vicinity of the proposed Project site are discussed in section of Resource Report 5. WBI Transmission has also established a continuing education program to enable customers, the public, government officials, and those engaged in excavation activities to recognize a gas pipeline emergency and report it to appropriate public officials. Draft 11-5 January 2015

9 WBI Transmission will provide appropriate training to local emergency service personnel before the compressor station is placed in service. WBI Transmission will continue to coordinate with local responders after the facilities are operational. After the station is operational, WBI Transmission plans to hold an emergency responder open house at the station itself Emergency Shut-down System Part 192 specifies that each compressor station must have an emergency shut-down system that can be manually operated from at least two points. In addition to having more than the two required manual shutdown points, WBI Transmission s compressor station will have a number of monitoring systems for the compressor and buildings that will initiate a shut-down automatically. The compressor unit building will also be equipped with fire, heat, and gas detection systems which would, based upon certain conditions, initiate an automatic shut-down. Draft 11-6 January 2015