{"operation":"document","citation":"PI-19-0001","title":"Town of Hopkinton — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2019-10-01","effective_on":null,"summary":"PI-19-0001 response to Town of Hopkinton concerning 193.2005, 193.2051.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-19-0001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-19-0001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-19-0001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/72521/town-hopkinton-pi-19-0001-10-01-2019-part-19320005-and-2051.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nofTransportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Avenue SE\nWashington DC 20590\nMr. J. Raymond Miyares\nTown Counsel\nTown of Hopkinton\n40 Grove Street\nSuite 190\nWellesley, MA 02482\nDear Mr. Miyares:\nIn a December 17, 2018, letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), you requested an interpretation of 49 CFR §§ 193.2005 and 193.2051. Specifically,\nyou asked iflengthening an existing liquefied natural gas (LNG) facility's piping would subject\nthe facility to Part 193, Subpart B regulations.\nBackground\nAccording to your letter, Hopkinton LNG Corp. (HOPCo) owns a peak-shaving LNG plant in the\nTown of Hopkinton, Massachusetts (Hopkinton LNG Plant). The Hopkinton LNG Plant has\nthree cryogenic LNG storage tanks, with associated vaporizer and liquefaction facilities. The\nplant is sited on two parcels of land that straddle Wilson Street, a public roadway in Hopkinton.\nThe existing vaporizer and liquefaction facilities are connected to the three LNG storage tanks\nthrough two pipelines that cross Wilson Street through a below-grade, concrete culvert\nperpendicular to and under the Wilson Street roadway. The piping enters the culvert a short\ndistance from the roadway on the eastern parcel, travels through the culvert below the roadway,\nand exits the culvert a short distance from the roadway on the western parcel. At the entry points\nfor the culvert on the east side of the roadway, the piping changes direction in an approximately\n90° tum twice - 90° downward until reaching the grade of the culvert and then 90° to run\nparallel to the culvert floor. At both the east-side entry point and west-side exist point, the\npiping is protected by metal fencing, boulders, concrete jersey barriers, and guardrails. Outside\nof the culvert, the pipes are suspended a short height above-grade, on concrete sleepers.\nYou indicated that HOP Co proposes to replace the plant's liquefaction facilities as part of an\nupgrade to the plant. That replacement project will remove the current liquefaction facilities on\nthe eastern parcel and replace them with new liquefaction facilities on the western parcel. The\nplant's existing vaporization facilities, however, will remain on the eastern parcel. Accordingly,\nthe two pipes crossing Wilson Street will remain in place and will continue to transport LNG\nbetween facilities on the two parcels.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nAs HOPCo replaces equipment at its LNG facility, the Town of Hopkinton also wants HOPCo to\nlengthen the distance between the roadway and the two pipes' entry and exit points. You believe\nthis action would push the above-ground length of the piping farther back from the roadway to\nlessen the possibility of accidental vehicle strikes to the pipes. You further indicated that this\nproposal would not move the existing piping from its current route between the existing\nvaporizer and liquefaction facilities. Rather, it would entail lengthening the below-grade culvert\nand shifting the 90-degree piping turns farther back from the roadway an equal distance. Finally,\nyou provided photos of the site and mentioned HOPCo's previous modifications to the plant's\nexisting vaporizer, which were not subject to the Part 193 siting requirements.\nPHMSA also received a March 11, 2019, letter from HOPCo~ which indicated that the company\nbelieves that the Town's proposed modification to the Hopkinton LNG Plant, which went into\nservice in the early 1970s, would likely require the facility to comply with the Subpart B, Part\n193 siting requirements. Specifically, HOPCo stated that at least some portion of the piping\nwould need to be lowered as part of the Town's proposal, and that lowering appears to qualify as\na relocation of an existing LNG facility (whether in terms of elevation from the ground or\ndistance from plant property lines or other LNG facilities) under the Part 193 regulations.\nHOPCo further indicated that the Town's proposal would also require the installation of at least\nsome new LNG piping;\nPHMSA shared this letter with you on April 1, 2019, via email, and you responded on April 22,\n2019, indicating that you had no amendments to your request for interpretation based on\nHOPCo's March 11, 2019 letter.\nQuestion\nWould the Town of Hopkinton 's proposed enhancement to the existing LNG pipelines at\nthe Hopkinton LNG plant constitute the replacement, relocation or significant alteration\nof the facility within the meaning of 49 CFR §§ 193.2005(b) and 193.2051 and, therefore,\nbe subject to siting requirements of 49 CFR Part 193, Subpart B?\nAnalysis\nPHMSA prescribes minimum Federal safety standards for the design, construction, operation,\nmaintenance, and security of LNG facilities. PHMSA has _promulgated regulations that govern\nthe applicability of the siting requirements to existing LNG facilities. In particular,\n§ 193.2005(b) states \"[I]f an existing LNG facility (or facility under construction before March\n31, 2000) is replaced, relocated or significantly altered after March 31, 2000, the facility must\ncomply with the applicable requirements of this part governing, siting, design, installation, and\nconstruction ...\n\"1 Additionally,§ 193.2051 states \"[E]ach LNG facility designed, constructed,\nreplaced, relocated or significantly altered after March 31, 2000, must be provided with siting\nrequirements in accordance with the requirements of this part and ofNFPA 59A (incorporated by\nreference, see§ 193.2013) ... \"\n1 See 49 USC§§ 60101(a)(l), (16), and 60103(c), providing that, with certain exceptions, a design, location,\ninstallation, construction, initial inspection, or initial testing standard prescribed after March 1, 1978, does not apply\nto an existing liquefied natural gas pipeline facility.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\n3\nBased on the facts represented by the Town of Hopkinton, PHMSA does not consider the\nTown's proposed enhancement to the existing LNG pipelines at the Hopkinton LNG plant to\nconstitute design, construction, replacement, relocation or significant alteration of the facility\nwithin the meaning of 49 CFR §§ 193.2005(b) and 193.2051. The existing LNG pipelines would\nremain in the same location and, therefore, would not be replaced or relocated. The change\nwould also not constitute a significant alteration because the LNG operating parameters would\nnot be affected by the proposed changes. Therefore, the proposed change in modifying the\nbelow-grade culvert and shifting the 90-degree piping turns farther back from the roadway would\nnot be subject to the Subpart B, 49 CFR Part 193 siting requirements. However, if these existing\nLNG facilities are otherwise replaced, relocated, or significantly altered (by using new piping as\nsuggested by HOPCo's March 11, 2019, letter), they may trigger the siting requireinents under\n49 CFR §§ 193.2005(b) and 193.2051.\nPlease keep in mind that this response letter reflects the agency's current application of the\nregulations to the specific facts you presented for clarification. Also, interpretations do not\ncreate legally-enforceable right~ or obligations and are provided to help the requester understand\nhow to comply with the regulations.\nIfwe can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the fonn of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or oqligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\nM iyares Harrington\nJ. Raymond Miyares Thomas J. Harrington Christopher H. Heep Donna M. Brewer Jennie M. Merrill\nRebekah Lacey Bryan Bertram lvria Glass Fried Eric Reustle Katherine E. Stock\nDecember 17, 2018\nBy: Overnight Mail\nJAN 3 0 20i9\nUnited States Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nEast Building, 2nd Floor\n1200 New Jersey Ave., SE\nWashington, D.C. 20590\nRe: Request for Written Interpretation of U.S. DOT Regulations\nDear Sir or Madam:\nOn behalf of the Town of Hopkinton, Massachusetts - for which I am the duly appointed\nTown Counsel - I write to request a formal written letter interpreting the Department of\nTransportation's regulations at 49 C.F .R. Part 193. I further ask that the Department expedite its\ntreatment of this request because it concerns the safety of an existing liquefied natural gas (LNG)\nstorage plant.\nBackground\nHopkinton is host community to the largest peak-shaving LNG plant in New England. It is\nowned by Hopkinton LNG Corp. (\"HOPCo\"), which contracts with NSTAR Gas Company, a\nsubsidiary of Eversource Energy, for peak-shaving capacity. The plant has three cryogenic LNG\nstorage tanks, with associated vaporizer and liquefaction facilities. The plant entered service in\nstages, beginning in the late 1960s. It is sited on two parcels of land that straddle Wilson Street, a\npublic way in Hopkinton . The three LNG storage tanks are located on the western parcel at 55\nWilson Street and the vaporizer and liquefaction facilities are located on the eastern parcel at 52\nWilson Street.\nThe existing liquefaction and vaporizer facilities are connected to the three LNG storage\ntanks through two pipes that cross Wilson Street through a below-grade, concrete culvert\nperpendicular to an.cl under the Wilson Street roadway. The piping enters that culvert a short\ndistance from the roadway on the eastern parcel (52 Wilson Street), travels through the culvert\nbelow the roadway, and exits the culvert a short distance from the roadway on the western parcel\n40 Grove Street • Suite 190 • Wei esley, Massachusetts 02482 I 617 .489 1600 I www.rniyares-harrington.com\nLocal options at work\n\n<<<PAGE 5>>>\n\nU .S. DOT\nDecember 17, 2018\nPage 2 of 6\n(55 Wilson Street). At the entry points for the culver t on the east side of the roadway, the piping\nchanges direction in an approximately 90° turn twice - 90° downward until reaching the grade of\nthe culvert and then 90° to run parallel to the culvert floor. At both the east-side entry point and\nwest-side exist point on the opposite side of Wilson Street, the piping is protected by metal\nfencing, boulders, concrete jersey barriers, and guardrails. Outside of the culvert, the pipes are\nsuspended a short height above-grade, on concrete sleepers.\nOverhead photo9raphs if f acility with Wilson Street pipe crossing circled in red\nLocal options at wort<\nMiyaresHarrington\n\n<<<PAGE 6>>>\n\nU.S . DOT\nDecember 17, 2018\nPage 3 of 6\nView ef pipe entering under-road culvert lookin9 eastjrom roadway\nView ef pipe entering under-road culvert lookin9 west from roadway\nLocal options at work\nMiyaresHarrington\n\n<<<PAGE 7>>>\n\nU .S. DOT\nDecember 17, 2018\nPage 4 of 6\nHOPCo proposes to replace the plant's liquefaction facilities as part of an upgrade to the\nplant. That replacement project will remove the current liquefaction facilities on the eastern parcel\nand replace them with new liquefaction facilities on the western parcel. The plant's existing\nvaporization facilities, however, will remain on the eastern parcel. Accordingly, the two pipes\ncrossing Wilson Street will remain in place and will continue to transport LNG between facilities\non the two parcels.\nThis replacement project is currently undergoing administrative review, in a proceeding for\na comprehensive zoning exemption, before the State's Department of Public Utilities. 1 The Town\nof Hopkinton has intervened in that proceeding, to ensure that the plant properly addresses all\nsafety and other concerns associated with the upgrade and future operations. In connection with\nthat proceeding, the Town has discussed with HOPCo the feasibility of improving the plant's safety\nwhere the existing piping crosses Wilson Street. One potential enhancement to the existing\nconfiguration would be to lengthen the distance between the roadway and the two pipes' entry and\nexist points from the below-grade culvert - i.e. pushing the above-ground length of the piping\nfarther back from the roadway. Doing so would enhance safety by moving the pipes farther from\nthe road, lessening the possibility of accidental vehicle strikes to the pipes, and increasing available\nspace for additional barriers and other pipe protection measures.\nImplementing such a change would not move the existing piping from its current route\nbetween the existing vaporizer and liquefaction facilities. Rather, it would entail lengthening the\nbelow-grade culvert and shifting the 90-degree piping turns farther back from the roadway an equal\ndistance. It is not contemplated that this would require any change in piping materials or to the\ncapacity of the pipes or their construction ( other than shifting the 90-degree turns). The sole\npurpose to this minimal change would be enhancing safety at the Wilson Street crossing. 2\nInterpretation Request\nThe Town of Hopkinton requests a written determination from the Department answering\nwhether the potential, proposed change to the Wilson Street pipes described above would\nconstitute \"design[ing], construct[ing], replac[ing], relocate[ing] or significantly alter[ing]\" a facility\nwithin the meaning of 49 C.F.R. §193.2005 and/ or§ 193.2051, thus making the proposed change\n1 Petition if Hopkinton LNG Corp. pursuant to G.L. c. 40A, § 3.for Individual and\nComprehensive Exemptions from the Zonin9 Bylaws ef the Town if Hopkinton, Mass. D.P. U. No. 17-114. All filings in that proceeding are available at\nhtt;ps:/ /eeaonline.eea.state.ma.us/DPU/Fileroom/dockets/bynumber by searching under docket numb~r \"17-114\".\n2 To be clear, the proposed project currently undergoing Massachusetts DPU review includes the construction of additional piping under\nWilson Street, adjacent to the existing piping. This letter, however, docs not request interpretation of the Department's regulations for that\nnew piping. Rather, this letter's request is limited to interpretation of the Department's regulations with respect to the existing piping, as\ndescribed above.\nLocal options at woric\nMiyaresHarrington\n\n<<<PAGE 8>>>\n\nU.S . DOT\nDecember 17, 2018\nPage 5 of 6\nsubject to 49 C.F.R. Part 193, Subpart B Siting Requirements, or any other of the Department's\nregulatory siting requirements.\nOf note, HOPCo previously performed a significant project on the plant's existing\nvaporizer, taking the position that the vaporizer project was not subject to Part 193 siting\nrequirements. HOPCo communicated to PHMSA, on or about December 22, 2015, that this was\nonly an \"in-situ\" replacement with OEM parts that would \"provide no additional vaporization\ncapacity\" and \"make no major changes to the original design or footprint of the equipment.\"\nHOPCO described the project to PHMSA as \"include[ing] the refurbishment of the existing\nconcrete vaporizer pits, replacement of sixteen natural gas fired burners and the associated fuel gas\npiping, electrical distribution, controls and combustion air blowers.\"3\nAs the Town understands matters, the vaporizer project required extensive replacement of\nvaporizer parts with new ones that, in turn, required designing a supplemental foundation to be\nlocated adjacent to the existing foundation. 4 It also required large-scale replacement of vaporizer\nparts. In contrast, the proposed change to the below-grade pipes under Wilson Street would\nrequire far less construction than the vaporizer project and would similarly require only \"in-kind\"\nreplacement of any parts as well as no meaningful change in the location of the pipes. Accordingly,\nthe Town can discern no reason why making those proposed changes to the pipes should be subject\nto Part 193 siting requirements, if the vaporizer project was not.\nThe Town asks that the Department render its interpretation as expeditiously as possible.\nThank you in advance for that consideration.\n3 These communications were specifically made to Mr. Joseph F. Klesin, Project Manager, Eastern Region of PHMSA. That communication is\nincluded as Attachment A.\n4 PowerPoint provided by Eversource in April 2016, included as Attachment Band letter from James P. Davis to Charles Kadlik, dated July 13,\n2016, included as Attachment C.\nLocal options at work\nMiyaresHarrington\n\n<<<PAGE 9>>>\n\nU .S. DOT\nDecember 17, 201 8\nPage 6 of 6\ncc.: Norman Khumalo\nTown Manager, Town of Hopkinton\nTown of Hopkinton Board of Selectmen\nHon. Karen E. Spilka\nPresident, Massachusetts Senate\nHon. Carolyn C. Dykema\nMassachusetts House of Representatives\nRichard Wallace\nDirector, Pipeline Safety Division, Massachusetts Department of Public Utilities\nN even Rabadjija\nDeputy General Counsel, Eversource Energy Service Co.\nLocal options at work\nMiyaresHarrington\n\n<<<PAGE 10>>>\n\nAttachment A\n\n<<<PAGE 11>>>\n\nEVERSS URCE\nENERGY\nDecember 22, 2015\nJoseph F. Klesin\nProject Manager - Eastern Region\nPipeline & Hazardous Materials Safety Administration\nUnited States Department of Transportation\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nSUBJECT: ER Request - Construction Projects for 2016\nDear Mr. Klesin:\nThis letter is in response to an email request, dated November 30, 2015, for the information related to\nsignificant construction projects to commence in 2016.\nThe following project has been identified as meeting the requirements set forth within the request:\nProject Name\nHopkinton LNG, Vaporizer Replacement Project\nLocation\nHopkinton, Middlesex County, Massachusetts\nProject Description\nThe Hopkinton LNG Plant has invested in the replacement of the existing vaporizers in order to ensure\nequipment and system reliability. The new vaporizer equipment has been provided by the Original\nEquipment Manufacturer (OEM) and will be considered an in-situ replacement. The new vaporizers will\nprovide no additional vaporization capacity and will make no major changes to the original design or\nfootprint of the equipment.\nThis project will include the refurbishment of the existing concrete vaporizer pits, replacement of sixteen\nnatural gas fired burners and the associated fuel gas piping, electrical distribution, controls and\ncombustion air blowers. The existing tube bundles, which were replaced in the mid 1990's, will be\nmaintained in their current state. This project is estimated at a total cost of approximately $14.5 million\nand will be constructed during the summer of 2016.\nType of System\nLNG, Submerged Combustion Vaporizers\nPage 1 of 2\n\n<<<PAGE 12>>>\n\nAnticipated Construction Start Date\nJune 1st, 2016\nAnticipated Construction Completion Date\nSeptember 30th\n, 2016\nAnticipated In-Service Date\nOctober 31st, 2016\nAs you can see this project is considered a maintenance activity taking place at an existing LNG facility.\nThe installation of equipment is expected to take place during the summer of 2016, contingent on the\ntimely delivery of the replacement equipment from the manufacturer.\nIf you have any additional questions or concerns please don't hesitate to contact me for additional\ninformation.\nSincerely,\nJim Blackburn, PE, PMP\nProject Manager, LNG\nOne NSTAR Way, NE380\nWestwood, MA 02090\nP: 508-813-6308\nJames.Blackburn@eversource.com\nPage 2 of 2\n\n<<<PAGE 13>>>\n\nAttachment B\n\n<<<PAGE 14>>>\n\nLt{ ~I ( k:>\nFacility Review\n• Constructed in 1967 by Tennessee Gas, the facility has been operated by Air Products since commissioning &\nowned by Eversource since 1970.\n• The facility provides supplemental capacity to constrained pipelines, serving as an emergency supply independent\nof interstate gas and maintains seasonal price stability for rate payers.\n• Connected to Eversource's gas distribution system, the facility serves over 300,000 customers in 36 towns, making\nup 40% of our customer's supply on the coldest days of the year.\n• Facility is regulated by MassDPU with oversight from PHMSA and FERC.\nProject Scope\n• Refurbishment of existing concrete vaporizer pits.\n• Replacement of existing power supply.\n• Replacement of the burners, fuel gas piping, electrical controls and blowers with new, in-kind, equipment\nsupplied by the original equipment manufacturer.\nProiect Benefits\n•\n•\nThis maintenance work provides for increased operator control, maintainability and is an upgrade to the design as\nit relates to safety and reliability of the equipment.\nNo increased capacity of the facility or changes to the environmental standard MassDEP holds us to.\n\n<<<PAGE 15>>>\n\nENERGY\nEVERSSURCE\nombustion\nFuel Gas\nLiquid NG In\nAporized NG Out\nVaporizer Refurbishment Project\nComb Air\nIntroduction to Vaporization\n\n<<<PAGE 16>>>\n\nENERGY\nosure\nEVERSEURCE\nvaporizers\n2i8-\nRestricted Land Use Buffer\n& Electri\nRestricted Land Use Buffer\nMassachuseis EDEA\nEntrance\nWilson St.\nVaporizer Refurbishment Project\nLegend\nce (HOPCO)\n712305940W clov\nKinder Morgan (Ten Gas)\nRafferty Rd.\nSite Plan\nPointer\n\n<<<PAGE 17>>>\n\n;j\n1,\n................................................. \\ ..\n. .\n; i ~~ t , gr > ;·:\ni, !:\nll\n' • i\nI ; -.\\1 I ' '\n. '> -\n. : I l\ni~:1\n--~':'1 :T----\n,\n'\n1,- -\n~ · :1\nAir :,\n~ ~ I\n• ti : I\n: I\n; I\n: I\n: I\n: I\n.\nl - .>I':'' -\ni\n'~\n-.c~.\nc;\"i'\"'\n~ .....L--~\n.\n\\\n\\\n~\nC\n:.,{,,◄\n-\n0-ti\n)\n♦\nl\n'\n.:.,\ni ,.\n~ -,ii ~,(\n\" 'i\n~ :;\nz,\nii\n.\n<>\niii\nal\n:F\n3\n* f\n-:::z-t\n\n<<<PAGE 18>>>\n\nI ~· <I) I 7iil\n<I) I\na5 I\n-o I\nc: I\nta '\n~ I\ncu I\n00 I\nfj I\n:!:: I\n3 I\nV) I\n3 I\nCl> I\nZI\nI\n'\n\n<<<PAGE 19>>>\n\nLocation of Replacement\nControl Panels\n·,~ - - - r-· - nr:·-::-,::__lf_ .:, ·-·\"\"!f\nJ - ·- LH.L.\n'--\nWalkway is to be Replaced\nLocation of New Power\nDistribution Enclosure\n\n<<<PAGE 20>>>\n\n~\n(II\n...\n(II -\n3 -. -\n0\nr:- C\n0\nm ~\n:::s\n.Q\n....\nc::\n'i:\n(II\n.... Ill\nIll (II\nE\n(II Q ...\n:::s\nu\nn, - J ... Ill\nCII 0\nQ. :-;,...,. __\n3 u\n0 c::\n(II s\na:: '\nQ,. LU\n....\n0 ; bO\n-,(\n~ ~\nc::\nc::\ni - --<=..-..:J . ~\n0\n•1 l Ill\n·x\nLU\nn,\nu\n.9\n\n<<<PAGE 21>>>\n\nConstruction Permits\n• Electrical Permit\n• Trench Safety Permit\n• Building Permit\nConstruction Details\n• All gas work is within the bounds of CFR 193\n• No wetlands in the area\n• Enclosure floor space is increased by 600 ft2\n• Location is isolated, in back section of property\n• All work is more than 75ft from existing fence line\n• 126 yds3 of spoils will be disposed of in accordance with MassDEP guidelines\n• Construction is scheduled from 7am to 4:30pm, Monday through Friday\n• Very limited public road use, minimal truck deliveries over the course of the project\n• Expect less than 25 additional workers on site\n\n<<<PAGE 22>>>\n\nAttachment C\n\n<<<PAGE 23>>>\n\nEVERSe URCE\nENERGY\nJuly 13, 2016\nCharles E. Kadlik\nDirector of Municipal Inspections - Zoning Enforcement Officer\nTown of Hopkinton\nOffice of Inspection al Services\n18 Main Street\nHopkinton, MA 01748\nSUBJECT: Explanation of Project Scope\nDear Mr. Kadlik:\nThis letter is intended to provide supplemental explanation and information regarding the building\npermit applications filed for the Vaporizer Refurbishment Project at the Hopkinton LNG facility.\nAs a general overview, the vaporization system at the Hopkinton plant is where liquid natural gas is\nwarmed and converted into a vapor state for use in the Eversource gas distribution system. The natural\ngas vapor produced at Hopkinton is distributed to area natural gas customers for their use on the\ncoldest days of the year when there are no other economical supplies of gas available. On a cold day all\nof Eversource gas customers in Massachusetts, including the Town of Hopkinton, depend on the\noperation of this facility for a significant portion of their gas supplies.\nThe vaporization system at Hopkinton has been well maintained over the years however a significant\nportion of the vaporization equipment is original at forty nine years old and requires investment. The\ninvestments are intended to maintain continued safe operation, improve reliability and modernize the\nsystem. The vaporizer system is not increasing in capacity, nor is the use of the system itself changing.\nLinde Engineering North America (LENA), the original equipment manufacturer ofthe existing\nequipment, was contracted and has provided replacement burners, combustion air blowers and controls\nto facilitate this investment effort and has produced technical equipment specifications demonstrating\nthat there is no change in system send-out or capacity. The vaporization system construction season is\nlimited to the summer months as this system must be available for operation fall, winter and spring. The\nfollowing sections provide supplemental information regarding the permit applications that have been\nsubmitted.\nPower Distribution Center {PDC)\nThe existing Power Distribution Center is being replaced with a new enclosure containing the\nreplacement electrical equipment. Due to current design standards, specifically the National Electric\nPage 1 of 2\n\n<<<PAGE 24>>>\n\nCode, the replacement enclosure needs to be slightly larger than existing to accommodate equipment\nremoval clearances and other changes inherent to the modern equipment size.\nIn order to maintain operation of the plant, it was necessary to install the replacement equipment at an\nadjacent location, while the existing equipment remained in service. After the replacement equipment\nis installed power will be cut over from the existing equipment to the replacement equipment. Once the\nreplacement equipment is in service, the old equipment will then be removed from service and\ndemolished.\nThe replacement PDC will be fed from the existing electric supply circuit, of which feeder circuit capacity\nis not changing.\nBlower Foundations\nLENA, as the OEM provider, specified larger combustion air blowers to comply with current air quality\nand emissions requirements for replacement equipment. There are four blowers in total being replaced\nall of which are supported on a single foundation. The replacement blowers will not physically fit on the\nexisting foundation. A replacement foundation has been designed to be located adjacent to the existing\nfoundation and will accommodate the increased blower size while complying with current American\nSociety of Civil Engineer's requirements.\nThe increase in blower size does not increase the capacity of the vaporization system. It is simply a\nphysical and technical design requirement to comply with emissions requirements that apply to the\nreplacement equipment.\nWe appreciate the opportunity to host the site meeting today. We are providing these additional details\nto specifically address possible areas of concern. Please do not hesitate to contact me if any questions\narise regarding this supplemental information or any other aspect of the permit applications and\nsupporting documentation.\nSincerely,\names P. Davis\nDirector of Gas System Operation\nOne NSTAR Way,\nWestwood, MA 02090\nP: 781-441-8941\nJames.Davis@eversource.com\nCC: Michael Shepard\nPage 2 of2","truncated":false,"body_characters":27870}