Update **** Breaking #Fracking

For the Detail People 
MegaThanks to Rachel!

We sent a lot of information to PHMSA and the governor, but you can get a sense of the real “meat and potatoes” by perusing this below - 2 pages only - including bullet pointed list of issues, which i am extracting from attachment 8 (full doc and all attachments are available at: https://drive.google.com/open?id=0Bw0uKc2rfP1fTVJlUnVJX2d0Rnc 

….During 2014 and 2015 construction seasons, VT DPS raised serious concerns regarding deficiencies in comprehensive written plans, specifications, and quality assurance programs to support construction activities. VT DPS issued Vermont Gas a Warning of Probable Violations highlighting, among other things, inadequate documentation, and directed Vermont GA to submit a welding program and quality assurance program, required under Vermont Gas’s CPG. However, Vermont Gas was allowed to commence and continue construction for several months in 2014 and 2015 in the absence of approved plans. The same was true in 2016 albeit regarding different plans and specifications. On December 8, 2016, the PSB approved a settlement agreement (MOU) between Vermont Gas and VT DPS, for serious electrical safety violations and levied a fine of $95,000 and directed Vermont Gas to take several remedial measures. Additional probable violations and construction concerns were found in 2016 in connection with 1) failures to follow project specifications and plans as written; 2) repeated installation of pipe section without proper padding and support; 3) unqualified personnel working on the pipeline, including qualified electrical safety personnel, two individuals responsible for identifying coating damage and holidays and their supervisor; 4) problems with adhesion of corrosion protection sleeves and the eventual determination that one batch of sleeves, from which over 360 had already been installed and 18% were already buried; 5) disagreement with contractors regarding replacement of pipe sections with anomalies; 6) problems with coating damaging on pipe bends and after HDD pull-through.

In addition to the above, evidence suggests that following potential violations of federal, state, and/or CPG requirements may have occurred but appear not have been addressed effectively by VT DPS since October 15, 2017 when safety concerns were originally documented and sent to PHMSA: 

·       Construction-related violations that were documented by VT DPS’s contracted inspector but for which there is no record of compliance actions or adequate corrective measures (VT DPS);

·       Operator Qualification violations (Vermont Gas) that were documented by VT DPS’s contracted inspector but for which there is no record of compliance actions or inspection of potentially affected sections of pipeline (VT DPS);

·       Inadequate company inspections of installed pipeline associated with the above operator qualification violations and with failure to follow written specifications and plans (Vermont Gas) and failure to require remediation of pipe sections inspected by non-qualified inspectors (VT DPS);

·       Failure to follow (Vermont Gas) and enforce (VT DPS) existing electrical safety plans and specifications for construction parallel to electric transmission lines after VT DPS notified Vermont Gas of problems and issued a Notice of Probable Violation (NOPV);

·       Failure (VT DPS) to refer probable worker safety violations to VT OSHA despite VT DPS’s explicit statement in the NOPV that the violations raised worker safety concerns; 

·       Non-compliance (Vermont Gas) and failure to enforce (VT DPS) conditions of a negotiated settlement of the same electrical safety NOPV;

·       Violations of plans and specifications regarding installation, support and padding of pipe sections (Vermont Gas) that were documented by VT DPS contracted inspector but for which there is no record of compliance action or inspection and remediation of pipe segments that may have already been improperly installed and/or were inspected by non-qualified personnel (VT DPS); 

·       Possible failure to follow approved project design, construction plans and specifications, CPG conditions, and easement agreements for pipeline depth and soil cover, and operation of the pipeline without proper inspection, remediation, or warnings to landowners regarding non-compliant soil cover and pipeline depth (Vermont Gas) and failure to inspect soil cover and pipeline depth for compliance with actual project specifications and plans, including CPG conditions and terms of select easement agreements, which far exceed federal minimums (VT DPS); 

·       Construction, installation and operation of an unpermitted temporary venting stack (Vermont Gas) that was not included in any approved construction design presented in Vermont Gas’s petition for a certificate of public good or submitted to the VT Public Service Board for review and approval – and failure to enforce existing design and construction plans and specifications or to require review and approval of new design, plans, and specifications in accordance with Public Service Board rules (VT DPS);

·       Incomplete written plans and specifications for hydrostatic testing and gas up regarding notification of owner of parallel electric transmission lines and incomplete documentation and mapping of pipeline segment in hydrostatic testing plan (Vermont Gas) and failure to enforce requirement for complete plans and specifications (VT DPS);

·       Non-compliance (Vermont Gas) with existing written plans and specifications for hydrostatic testing and gas up and failure to enforce adherence to specifications and plans (VT DPS) regarding notice to the public, municipal authorities, and first responders prior to hydrostatic testing, and to local law enforcement prior to gas up (Vermont Gas) and failure to enforce compliance with plans and specifications (VT DPS);

·       Failure to protect and mainline valves from flooding and other potential environmental corrosion hazards (Vermont Gas) and failure to address flooding in an effective or timely manner (Vermont Gas), and failure enforce minimum federal standards and written plans and specifications (VT DPS);

·       Failure to complete and secure mainline valve facilities and an unpermitted temporary vent stack prior to operation, and failure to secure them from tampering prior to or during operation (Vermont Gas), and failure to enforce minimum federal and CPG standards for protecting mainline valves from tampering (VT DPS);

·       Operation of pipeline segments, mainline valves and an unpermitted temporary valve stack, in contravention of plans, specifications and requirements of the CPG, including inoperable AC corrosion mitigation, cathodic protection, and remote valve control, and unpermitted and non-compliant placement of object on mainline valve vent stack (Vermont Gas), and failure to enforce minimum federal standards and CPG requirements (VT DPS);

·       Failure to update public awareness plans to take into account location of newly constructed and operated transmission pipeline in communities with no prior experience with natural gas transmission and/or distribution prior to operation of new facilities (Vermont Gas) and failure to enforce requirement that plans include measures to reach all communities and all target populations (VT DPS);

·       Failure to carry out Vermont Gas or require (VT DPS) any public education and awareness activities with any target audience in areas where the pipeline was constructed and is in operation and failure to provide accessible emergency guidance to communities and residents along the new pipeline route prior to gas up or since pipeline segments were put into service (Vermont Gas) and failure to enforce public awareness standards (VT DPS);

·       Failure to coordinate (Vermont Gas) and to enforce requirements for (VT DPS) coordination of development of emergency response plans with local first responders in accordance with federal requirements and with regional planning commissions as stipulated in the CPG; 

·       Failure to comply with written plans and specifications regarding emergency response resources and to joint planning with local authorities and emergency responders prior to hydrostatic testing, gas up or operation of newly constructed pipeline facilities in communities unfamiliar with natural gas transmission and/or distribution (Vermont Gas) and failure to enforce federal minimum standards and CPG conditions;

·       Operation of pipeline without full compliance with soil cover and pipeline depth plans and specifications (Vermont Gas) and failure to enforce federal minimum standards and CPG conditions (VT DPS);

·       Dissemination of false information to public regarding odorant release event (Vermont Gas and VT DPS) and failure to require operator to correct already published false information regarding odorant release and migration event (VT DPS);

Dissemination of false information about operator compliance with federal minimum safety standards and CPG construction conditions (Vermont Gas and VT DPS) and failure to require that operator cease to publish false information regarding compliance with federal, state, and permit construction and pipeline safety requirements (VT DPS). 

THAT’s ALL FOLKS!