20 Questions for Otsego XNG #BombTrucks

"When submitting your comment (on paper cards),
Feel Free to use any of these questions. Be sure to
KEEP SCORE of how many of these get answered!"

 

Electeds::
"Don't let XNG take this meeting over.
You must ensure these questions get answered!
and Protect Public Safety!"

These are my general categories for the questions:

• Do we have an accurate understanding of the
  Dangers of these Trucks?
• Are Emergency Responders Prepared for dealing with this?
  
• Were the At-Risk Communities along the route part of the approval process?
  
• Have the Risks Been Accurately Assessed? (QRA)
• Have the Risks been Mitigated? (vs. Profit Margin, corporate Risk/Benefit analysis)
  
• Environmental Impact Statement / NEPA & SEQRA
  
• XNG Operational Issues
• XNG is a BAD ACTOR-- the worst in a league of pirates, theives, and liars
  
• Failure of the State (inc. Feds) to Regulate a new industry

--------------------------------

HERE IS THE REASON (IMO) FOR THE REGULATORY FAILURE:

1. Virtual Pipeline #BombTrucks are brand new (Just 5 years on US roads)
2. The law is silent on #BombTrucks, because they are new.
3. Regulators are empowered by the statutes.

Conclusion / PARADOX:
When some new threat comes to town which was not anticipated by law,
then the regulators will clearly lack the authority to deal with it. 
SUCH A SITUATION REQUIRES EMERGENCY ACTION FROM THE STATE
in order TO PROTECT LIVES.

---------------------------

How many agencies took a pass?
NYS PSC, FERC, US DOT, NYS DOT, PennDOT...?

What happens if the First Responders -- chartered to protect public health and safety
-- get too cozy with the greatest threat to public health and safety?

We have seen this in Pennsylvania in many different contexts:

(Police, Fire, and Hospitals take money from industry, then perform questionably
during an incident involving the grant-maker corporation, which happens also
to be a great threat to public health and safety).


MOST IMPORTANT QUESTIONS

TOPIC: Before we can create an Environmental Impact Statement,
or a Quantitative Risk Assessment, we need to know two things:

1) Potential Impact Radius (for BOTH explosion and fire)
2) The Exact Routes used to Customers.

We know NEITHER of these things!

Here are questions which drive this home:

• What is Potential Impact Radius of a Hexagon Titan or a Quantum VP-Lite trailer
  under a worst-case explosion scenario? (Explosive PIR)
  
• What is the Potential Impact Radius of a Hexagon Titan or a Quantum VP-Lite trailer
  under a worst-case fire scenario? (Thermal PIR)
  
  
• Describe the routes XNG drivers take to each customer. 

We DO NOT KNOW the risks now! We are just guessing. We lack critical data.

• Have the Risks of this activity been accurately assessed?
  
• Does a Quantitive Risk Assessment exist for this activity?
  
• Have the identified risks been Mitigated?
  
• How did XNG's Profit Margin impact the choice of driving these trucks
  corporate Risk/Benefit analysis
  

Are all applicable laws being followed?

• Have the FMC requirements for HAZMAT training been followed, etc?
  
  
• Does XNG require their drivers to follow all applicable laws,
  local, DOT, FMCSA, HAZMAT, OSHA, etc.?

Who Regulates?
Failure of the State (inc. Feds) to Regulate a new industry

• Have the SPECIAL RISKS of these brand-new Type-4 CNG trailers been evaluated
  by ANY Federal or State Regulatory Agency?
• US DOT? 
• PHMSA?
• FMCSA?
  
• FERC?
  
• NYS DOT?
  
• PennDOT?
  
• NY PSC or PA PUC?
  
  
• Has US DOT performed destructive testing of these high-capacity Type-4 carbon-fiber
  CNG trailers under real-world situations?
  
  
• Let's see the videos, with crash test dummies, of how a Hexagon Titan or Quantum VP
  with a full load of methane behaves
  
  
• in a diesel fire?
  
• hit with armor piercing rounds?
• head-on collision @ combined 120 MPH

Are Drivers Qualified?

• Do you drivers undergo any special training on each tractor-trailer configuration?
  
• Do your drivers take 3-day qualification test with an experienced driver?
• Do you only hire experienced HAZMAT drivers?
• Do you have a high turnover rate of drivers?
  

Are Emergency Responders Prepared for dealing with this?

• If a trailer is on fire, should you douse it with water, or not?
• Does dousing with water create a greater risk of explosion?
• Is it "better" for the Pressure Relief device to blow in a fire, creating a massive flamethrower,
  or is it better to keep the PRDs cool, and allow the tank to explode?
  

Approval Process:

• Were the At-Risk Communities along the route part of the permitting and approval process?
• Were there any public hearings along the route?
• Were there Public Scoping sessions?
• Were the communities along the route, especially the people living and working within either the Explosive PIR or the Thermal PIR notified of this operation?

Specific Hazards of this Route:

• How many Day Care Centers, Hospitals, Schools, Shopping Centers,
  and Apartment Buildings, and Residential homes exist along this route?
  
• What about gas stations, bulk chemical storage or other hazards?
  What about critical infrastructure like electric substations?
  
  
• What could go wrong when Overweight, Misconfigured Trucks, pulled
  by underpowered tractors, with inadequate brakes, travel down a road
  with a 9% grade with an electrical substation at the bottom, in the winter
  when it's snowing? Times 100+ trips per day?

XNG Operational Issues

• What happens if there is a road closure (e.g., accident or snowstorm) along the route.
  
• Do the trucks shelter in-place?
  
• Do they make a Turn Around and go home?
  
• Or do they stack up at the end?
  
• What exact hazard or weather conditions would cause XNG to stay on the interstate?
• Do any of your tractors or trailers have safety features disabled?
• Are your Titans or Quantum trailers equipped with burst disks? Have these been disabled?
•     Why do your trucks drive in clusters of 2 or 3?
  
•     Do your trucking logistics change at night?
      (greater volume? different routes? different equipment? heavier loads?)
  
•     Do your Electronic Log Devices transmit telemetry data reliably at every point along the route?
• Describe your process of filling a trailer.
  
• Do you Double Fill your trailers? Why?
• Do you fill your trailers to more than 3,600 psi?
• Are the CNG Freightliner Cascadia tractors rated for only 60,000 GVW?
  
• What is the risk to public safety if an 81,000 lb GVW combo carrying HAZMAT is pulled by a tractor rated for 60,000 lb GVW?
  
• How much do you trailers weight? Loaded? Unloaded? (Quantum, Titan, Lightstore)
• There were several press stories that XNG had purchased Quantum VP-650s and Titan-XLs.
  
• Do the CNG Freightliner Cascadia tractors have a functioning Jake Brake, or Engine Retarder?
  
• Do the CNG Freightliner Cascadias have known defects with the steer-axle?
  
• A Virtual Pipeline is a midstream company. You don't own the gas.
  Who are your actual customers on each end? Buyers and Sellers?

Weight / Scales:

• Is it true some of your combinations have been weighed in excess of 80,000 lbs?
• When a driver or yard master changes a tractor from a Quantum to a Titan, is the Fifth Wheel adjusted to this new load configuration?
• What are the risks if a tractor's fifth wheel is not adjusted correctly?
  
• Are all of your trucks equipped with a functioning 5th-Wheel Trailer Hitch Weight Scale?
• Do you have scales at either Manheim Station or Forest Lake?
  
• Do you avoid scales for a reason?
  
• Why don't you take the interstate, I88, which is safer, and where there are scales?
  
• If you don't weigh your vehicles, how can you be sure they are not overweight?
  
• Have your vehicles ever been found to be over 80,000 lbs GVW?
  

Trucks / Trailers Liability

• Do either XNG or the trailer manufactures have insurance to underwrite the risks involved?
  
• Who assumes the risks these trailers create by travelling through our neighborhoods?
  
• If it is found that a Hexagon or Quantum CNG trailer is defective,
  and people are injured due to the defect, are these companies adequately
  bonded to cover a possible worst-case catastrophe?
  
• What do the balance sheets of Hexagon and Quantum look like?
  
• Have either Hexagon or Quantum declared bankruptcy? or are near such?

Environmental Impact Statement:

• Was an Environmental Impact Statement prepared under either federal (NEPA) or State Law (SEQRA)?
• Who was the lead agency?
• Where there public hearings or public scoping sessions?
• Were the routes examined as part of a comprehensive EIS?
  

XNG is a BAD ACTOR-- the worst in a league of pirates, theives, and liars

• Do you have a permit for your two compressors in Pennsylvania?
  
• Do you have a permits for *any* of your 5 (or 6?) compressors in Manheim?
  
• Do you have tracking devices which track speed, location, and weight of your vehicles?
  
• Do you you encourage your drivers to speed?
  
• Are you aware that your drivers routinely drive with excessive speed and have been reported driving aggressively?
  
• When you Electronic Log Device records excessive speed,
  what is your policy for citing drivers?
  
• Do you issue tickets to all drivers who are detected speeding?
  
• How can you be legally engaged in bulk, wholesale, interstate commerce in natural gas,
  when you are operating without a Natural Gas Act Section 7 FERC Certificate of Public Convenience for either
  Manheim Station or Forest Lake, as is required by law?
• Do your vehicles have adequate brakes and power for the hilly route you've chosen?
  
• Your drivers have been observed "riding their brakes" down the Mohawk Valley hill. Does this create a safety risk?
  
• There is one point along the route where 80 intersects 28, where there is a steep 9% grade, and an electrical substation at the bottom of the hill.
  My question is, what could go wrong?
  
• Matt Smith wrote to Art Klingler on Sept 12th and said, "Please know - again - the trucks CANNOT explode (physically impossible)". SEE ATTACHED IMAGE BELOW.
  Really?
  
  
  
• What about the many videos of CNG buses, and garbage trucks with the same type of Type-4 Carbon Fiber Tanks (only smaller) exploding.
  

Safety Incidents

• How many safety incidents have you had since operating PA or NY?
• How many motor vehicle accidents?
• Have any of your trailers vented, either at the depot or on the road,
  due to equipment failure, over pressurization, or other reason?
• What happened to the trucks and trailers in the 3 prior rollover accidents?
  
• What happened in Binghamton on May 27, 2017 which was reported to the National Response Center? Was I-81 closed at Front Street and why?
  
• Have First Responders ever reported a visible vapor cloud close to the ground during an emergency venting situation? Is this contrary to what you tell people?
  
  

OSHA questions

• Do you make your drivers complete two full runs in a shift?
• Do drivers ever have to work more than 12 hours?
• Do you require drivers based on either Montrose or Manheim to being their shift at a drop-yard?
  

Missing Permits

• Do you have a bulk storage permit for 440 Prentice Road or any of your drop yards?
• What is the purpose of your facility at 440 Prentice Road, in Vestal?
  
• How many drop yards do you maintain? Locations?
• Did XNG petition the NYS PSC for a declaratory order seeking a lack of jurisdiction?
  
• Did XNG petition FERC for a declaratory order seeking a lack of jurisdiction?
• Did XNG apply for air quality permits for any compressors at Forest Lake?
• Did XNG apply for air quality permits for any of the electric compressors at Manheim?
• Did XNG apply for air quality permits for any of the gas-fired compressors at Manheim?
  
• How many gas-fired compressors at Manheim?
• You told Town of Manheim in 2016-2017 that you were adding a "5th compressor".
  Did you also tell Town of Manheim this new compressor was gas-fired?
• Did you inform the NYS PSC, the NYS DEC, or FERC of your intention to reverse the flow at Manheim?
  

LNG?

• We've heard XNG has applied for a permit for an LNG facility at Forest Lake.
  We know you are already overweight with less exotic CNG trailers.
  What is the use-case for LNG?
  

Exports?

• We know these trailers are actually ISO shipping containers. Are you planning on doing CNG on LNG exports?
  

UNLOAD PROCEDURE:

• "At any point during unloading,
  are your trailers exposed to a vacuum?"

  (Yes they are, and it voids the warranty. The big compressor
in Manheim is essentially a vacuum cleaner which sucks out the gas)

• How long doe it take to fill a trailer?
• How long does it take to unload?
• Are these type-4 tanks ever empty?
• What percentage of the unload cycle are these tanks exposed to a vacuum?
  
• At the Otsego County incident 9/12/2017:
  Why were the 2,000 lbs of gas in the fuel tanks vented, but the 2,000 lbs of gas in the storage tanks not vented?
Regarding the 3 tractor-trailers which experienced rollovers or tipovers, what happened to the tractors?
What happened to the tank container, and the chassis? Where any of these parts put back into service?