A Pipeline “System Upset Condition” Is “Of Substantial Concern” to South Jersey Gas Co.

If  risks are “of substantial concern” to SJG, they must be of even greater concern to the Pinelands Commission 

Opponents of the South Jersey Gas Co. proposed pipeline through the Pinelands National Reserve have cited data and numerous examples of pipeline safety failures that have led to explosions, fires, fatalities, and property and environmental damage.

In response, instead of addressing those issues substantively, these issues have been ignored or the opponents been accused of fear mongering and “emotional” appeals (e.g. see the AP story that went national).[or this condescending, fact free, ill informed and flat out factually incorrect (no compelling need was required or even attempted to be demonstrated – that is the waiver standard) editorial by the  Press of Atlantic City ]

However, in South Jersey Gas Co.’s (SJG) petition to the Board of Public Utilities (BPU),  the Company explains the reason they need the “Reliability” gas line.

Basically, SJG says they need the “reliability line” because the existing pipeline is vulnerable.

SJG notes that a “system upset condition” along the existing gas pipeline infrastructure is of “substantial concern” to the company.

Such a “condition” –  a vulnerability ascribed vaguely to actions by “careless third party excavators” or “external forces” – would knock out gas service to 60,000 residential and commercial users in Cape May county: (Source: SJG petition to BPU – 10/31/13)

The BPU petition does not include “system upset conditions” resulting from pipeline design, construction, or operation.

When I asked a SJG official what a “system upset condition” was defined as, he replied that those conditions could include:

seismic event (earthquake); terrorism; explosion; fire; damage by excavation along the pipeline route; leak; loss of pressure; etc

So, in translation, I guess that means that shit happens.

But what is the probability that shit might happen?  How do we reduce that probability? What would happen if shit happened? What would be the result and impacts?

Is that an acceptable risk?

So, if the existing gas line is vulnerable to a “system upset condition”, doesn’t it logically follow that the new pipeline would be vulnerable as well?

How could pipeline design and construction avoid “external forces” like earthquake, terrorism, and excavation?

SJG acknowledges that the existing gas infrastructure is vulnerable. In fact, they base the need for the project on precisely such vulnerability resulting from vague “system upset conditions”.

Curiously, while they note the vulnerability of the existing gas infrastructure to “system upset conditions”, they do no admit the existence of such vulnerabilities for the proposed new pipeline.

Nor do they describe or discuss specific kinds of “system upset conditions”; what the probability and risks of such conditions are; or what the impacts of such conditions would pose for the Pinelands forests or the people who live there.

That is a glaring defect in the rationale for this project and its review by BPU, DEP, and the Pinelands Commission.

Sorry guys, “just trust us” is not an acceptable regulatory practice.

SJG can not have it both ways – if the existing pipeline infrastrcutreu is vulnerable to “system upset conditions”, then the new pipeline is vulnerable as well.

Those vulnerabilities must be honestly and transparently characterized, quantified, analyzed, prevented, and mitigated.

And if those vulnerabilities are “of substantial concern” to SJG, they must be of even greater concern to the Pinelands Commission in reviewing the proposed pipeline.

Thus far, that has not been the case.