IBEW, Fitters Locked Out by Construction Standards for the Milford and Easton Compressor Station Expansions

By Alex Lotorto - IWW Environmental Unionism Caucus, July 18, 2014

Disclaimer: The views expressed here are not the official position of the IWW (or even the IWW’s EUC) and do not necessarily represent the views of anyone but the author’s.

To: Executive Board, Officials, and Business Agents, et al.

• United Association Local Union 524
• IBEW Local 81
• IUOE Local 542
• Teamsters Local 229
• LIUNA Local 130

From:  Alex Lotorto

• Union Delegate, Industrial Workers of the World
  
• Organizer, Energy Justice Network
• p. 570-269-9589
• e. alex@energyjustice.net

Electrical Workers, Fitters are Locked Out By Construction Standards for the Milford and Easton Compressor Station Expansions

The proposed Milford and Easton Compressor Station expansions are part of Columbia Gas Transmission Co.’s (subsidiary of NiSource) East Side Expansion Project. Both proposed expansions do not utilize industry best practices to reduce or eliminate emissions that also require more manhours to install. This means that NiSource, which earned $5.7 billion in net revenue last year, is minimizing its costs, effectively swindling trade union members out of the best possible Project Labor Agreements. In this case, the cause of labor is also aligned with the cause of local environmentalists who seek to limit unnecessary harm to public health and air quality.

Specifically, it has been established by the gas industry associations and the Environmental Protection Agency’s Natural Gas Star program, that electric compressors, gas capture technology, and limiting production tank emissions are now the best practices for protecting air quality during transmission and distribution of natural gas. Columbia Gas is a partner in the EPA’s Natural Gas Star program and should be aware of their own recommendations.

In fact, technology like electric compressors and gas capture methods that eliminate blowdowns of methane during maintenance and inspections can pay for themselves as more methane is shipped to downstream customers. Methane that is now released into the atmosphere during blowdowns could be injected into the intersecting Tennessee and Transco pipelines at the Milford and Easton facilities, respectively, and sold to market. This would generate savings for NiSource within one to three years, depending on the price of methane. Above, you will find links to fact sheets for these technologies from the EPA, produced via industry partnerships.

Commonly, best practice recommendations become codified in EPA regulations once they have been shown to work in the field. This is the case for production tank rules limiting volatile organic compounds (VOCs) emissions to less than four tons per year, about to be enforced in January 2015 . Both Milford and Easton facilities will have waste liquid and condensate tanks that will be required to be fitted with VOC control technology next year. However, NiSource stated to Milford residents in pre-filing meetings that they will not be installing this technology, meaning lost work for union members and more exposure for neighboring families. In fact, there is nothing in their Resources Report submitted to the Federal Energy Regulatory Commission describing VOC controls. There is also nothing in the Resources Report describing how hazardous waste will be tended, removed, and disposed of from the facilities, a responsibility best handled by trained union labor.

Our IBEW brothers and sisters are essentially locked out of the job to install electric compressors if the proposal goes to construction phase. Fitters are locked out of work installing blowdown injection valves and vapor recovery systems on the condensate tanks. This is intolerable to me both as a union delegate and a Milford resident concerned about air emissions. If the work is to be done, it should be done according to the highest standards, with respect for northeast Pennsylvania workers. The project, as proposed with combustion engines, is a bad deal for workers and the environment and should be re-engineered and resubmitted for permitted with industry best practices.

I am seeking an advocacy relationship with fellow union officials who are interested in challenging NiSource’s current proposal to demand the use of best practices that eliminate harmful emissions and create more jobs for local union members. As Project Labor Agreements for the East Side Expansion Project are finalized, I hope that a cross-section of the trades will demand that best practice technologies are installed. I can guarantee that local environmentalists will stand by you if you choose to flex your muscles should the company refuse to stop busting your members out of honest work. This could also set the industry precedent for use of compressor station best practices throughout the Mid-Atlantic region, yielding more work for your members for years to come.

Our leverage over NiSource’s heads is very simple: On August 1, the one thing they will fear most is a united front of local environmentalists and union members picketing the construction. This is an opportunity for environmentalists and labor to join in common cause, claiming victory for workers and clean air from a company that would sacrifice both for its bottom line if we let them.

Links:

• FERC Application
• Resources Report
• EPA Natural Gas Star - Electric Compressors
• EPA Natural Gas Star - Blowdown Prevention
• EPA Production Tank Rule
• EPA Natural Gas Star - Partners List (includes Columbia Gas, NiSource)

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Background from NiSource’s FERC permit application

Milford Compressor Station

Milford CS (“Milford”) is situated in Milford, Pike County, Pennsylvania, and was

constructed and placed in-service in 1956. Columbia has historically used Milford to boost receipt volume from Tennessee Gas Pipeline Company, L.L.C. (“Tennessee”) into Columbia’s Line 1278. Columbia proposes to abandon all of the facilities associated with the existing station and replace those facilities within the station’s existing property boundaries with new equipment sized for the increased capacity required for the project.

The two existing reciprocating compressor units that produce 680 HP, and the associated auxiliary equipment, will be replaced with two 4,700 HP (ISO) Solar Turbines (“Solar”) Centaur 40 gas turbine/compressor units and auxiliary equipment. In addition, the new facility will be designed for bi-directional flow capabilities, and approximately 700 feet of 12-inch station piping between Line 1278 and Tennessee’s system will be replaced with 20-inch pipe to accommodate the additional flow. Upon installation of the new turbine/compressor units, Milford will have 9,400 HP operating at the station.

Columbia chose the Centaur 40 units for Milford CS because they are the smallest Solar units available with SoLoNOX capability that can perform the work required. Columbia proposes to certificate each of the Centaur 40 units at their maximum capable HP of 4,700 HP per unit. Columbia recognizes that its Exhibit G diagram identifies a peak day need of 5,946 HP, while Columbia is proposing to place the full 9,400 HP from the two Centaur 40 units in service. Columbia notes that peak day represents only a single operating scenario with certain specific load conditions, however, Columbia will experience other operating scenarios throughout the year during which it would be required to operate the Milford CS in modes that require more HP than peak day requirements. For example, in addition to the inherent increase in flexibility, having additional HP to meet market requirements would be crucial should other pipelines experience lower pressures on their systems. For instance, with the availability of the maximum HP, Columbia would have the option of accessing that HP to manage lower delivery pressures from upstream pipelines, and potentially avoid influencing how Columbia operates its eastern most storage facilities during non-peak periods. That in turn will enhance overall reliability and flexibility realized by its ESE shippers along with its base system shippers.

Finally, Columbia estimates that operating the units at their maximum HP would create approximately 9 Mdth/day of additional capacity between Milford CS and Easton CS for new markets served directly from Line 1278. At the time of the instant filing there are no markets directly attached to Line 1278 capable of utilizing this capacity. Columbia will make the additional capacity available to any existing or new customer capable of receiving the gas without additional investments by Columbia. In addition to the foregoing, using the maximum HP also creates a minor increase in firm local receipt and delivery capacity on Line 1278 immediately south of Easton CS.

However, there are no markets currently connected to Columbia's system within this very short section of pipeline, e.g., significantly less than 10 miles south of the station.

Easton CS (“Easton”) is located in Easton, Northampton County, Pennsylvania and commenced operation in 1971.3 Columbia currently operates two Solar Saturn turbine units producing 2,240 HP that drive centrifugal compressors, and a 650 HP Waukesha L5790G reciprocating compressor, totaling 2,890 HP at the station. The two Solar Saturn units are primarily used to pump gas in Line 1278, and are presently capable of bi- directional flow. The Waukesha unit will be retained to continue delivery of interstate gas to Transcontinental Gas Pipe Line Company LLC. The two existing Solar Saturn units and auxiliary equipment will be abandoned and removed, and two 10,802 HP (ISO) Solar Taurus 70 turbine/compressor units and auxiliary equipment will be installed within the boundaries of the existing station property. Following installation of the new turbine/compressor units Easton will have a total of 22,254 HP operating at the station.

Columbia chose the Taurus 70 units for Easton CS because they are the smallest Solar units available with SoLoNOX capability that can perform the work required. Columbia proposes to certificate each of the Taurus 70 units at their maximum capable HP of 10,802 HP per unit. Columbia recognizes that its Exhibit G diagram identifies a peak day need of 17,912 HP, while Columbia is proposing to place the full 21,604 HP from the two Taurus 70 units in service. Columbia notes that peak day represents only a single operating scenario with certain specific load conditions, however, Columbia will experience other operating scenarios throughout the year during which it would be required to operate the Easton CS in modes that require more HP than peak day requirements. The same operating benefits and implications for capacity described above for Milford, will also result from operating the proposed Easton turbine units at their maximum HP.